Corrective Action Plans

Finding 389706 (2023-003)

Material Weakness 2023

KS

Student Financial Aid Reporting Internal Control / Segregation of Duties

Views of responsible officials and planned corrective action: Areas of focus will be to put in place written policies in procedures for the Financial Aid office, including the area of enrollment reporting, which is also done by Institutional Research, to provide appropriate updating of the NSLDS rec...

Views of responsible officials and planned corrective action: Areas of focus will be to put in place written policies in procedures for the Financial Aid office, including the area of enrollment reporting, which is also done by Institutional Research, to provide appropriate updating of the NSLDS records. This will include creating checks and balances to be sure that enrollment reporting is working and being updating timely. The Federal Student Aid website offers many resources in the form of training, including access to on-demand resources which provide a documented learning assessment. Our objectives will be that all current and incoming Financial Aid staff, along with Institutional Research staff, will be required to undergo training in the area of enrollment reporting, including the supervisor with whom the Financial Aid office reports to. This training will be annually and periodically throughout the year. In addition, daily add and drop reports are generated which would allow more frequent updating of the NSLDS system. Objectives will be to put in place to provide checks and balances to be sure that enrollment reporting is timely. Measurable targets will be achieved by documenting the training within a shared electronic drive between the supervisor and the Financial Aid office. The Financial Aid office shall be responsible for monitoring that the enrollment reporting is being done timely. In addition, periodic and monitored checks-ins of staff in Institutional Research with whom the responsibility to update NSLDS is with.

View Audit 300625

Finding 389705 (2023-002)

Material Weakness 2023

Fort Scott Community College

KS

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

Views of responsible officials and planned corrective action: Areas of Focus will be in the documentation of polices and procedures to provide clear expectations of internal control documentation used to complete the drawdowns from the Department of Education and for a process of record retention. O...

Views of responsible officials and planned corrective action: Areas of Focus will be in the documentation of polices and procedures to provide clear expectations of internal control documentation used to complete the drawdowns from the Department of Education and for a process of record retention. Our objective would be to formalized the policies and procedures be updated in the Financial Aid policy manual with shared access between the Financial Aid office who approves the aid, the Business Office who ultimately pulls down from the Department of Education, and with the Cashier who distributes any refunds. We have put in place an electronic folder with restricted access to provide confidentiality and provide documentation of the shared communication between offices. The POISE system already generates a listing of students. That workflow will be amended to retain that documentation to be available. Measurable targets will be to do this weekly or as batches are prepared for draw-down. This documentation will be found in the shared electronic folder, which has already been implemented. The transfer of student records into the financial system is being done weekly and documentation is retained of students for which transactions occur.

View Audit 300625

Finding 389692 (2023-003)

Significant Deficiency 2023

Grossmont-Cuyamaca Community College District

CA

Special Tests & Provisions Student Financial Aid Significant Deficiency

Two staff members were assigned the responsibility and access to EDExpress, which allows the college to send and receive files (including ISIRs) between college and federal databases. Both employees were placed on immediate and unanticipated leave in March 2023, leaving interim staff without the acc...

Two staff members were assigned the responsibility and access to EDExpress, which allows the college to send and receive files (including ISIRs) between college and federal databases. Both employees were placed on immediate and unanticipated leave in March 2023, leaving interim staff without the access or authority to perform these functions. It took some time to update the school’s online access and we were instructed to start using a different software, EDconnect, since EDExpress was becoming obsolete. Administration rights and training were then given to interim staff on uploading ISIRs into the FA system (SAM), and written procedures were developed. In the case cited here, the student was paid just as the staffing and access issues occurred. Updated records were not downloaded until after access to EDconnect was implemented and staff received guidance on the correct procedure. Initially, the student’s file did not require verification prior to payment, but changes made to their FAFSA generated ISIR #2 which resulted in a new request for verification. This update was received late due to the access and software issue. Since that time, we have developed written procedures on this process and trained additional staff. We have also created a new awarding and disbursement process and timeline, including required reconciliation of COD authorizations versus student awards and disbursements. This ensures students are properly awarded and disbursed, and that records between the two systems match. Uploads and downloads are now performed multiple times per week to ensure records are frequently updated. In addition, the Financial Aid Office transition from the SAM to the Colleague Financial System will automate these functions to run daily, eliminating the need for manual uploads and downloads of data between the systems. Staff absences will no longer impact the timely updating of records.

View Audit 300598

Finding 389691 (2023-002)

Significant Deficiency 2023

Grossmont-Cuyamaca Community College District

CA

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

Due to a sudden and unanticipated staffing shortage, R2T4 calculations were performed beyond the required timeframe. In the case where a student receives all F’s on their transcript, we cannot determine the students’ last date of attendance or academic activity, since F grades do not include this in...

Due to a sudden and unanticipated staffing shortage, R2T4 calculations were performed beyond the required timeframe. In the case where a student receives all F’s on their transcript, we cannot determine the students’ last date of attendance or academic activity, since F grades do not include this information (unlike W grades) and the college is a non-attendance taking institution. In this case, federal guidelines allows schools to use the midpoint of the payment period for the calculation. In these cases, all calculations would be based on the same date each term. In review of FA22 records, the calculations were performed in March 2023, but the withdrawal dates used to calculate eligibility were 10/21/22, the FA22 term midpoint. All policies and procedures relating to R2T4 processing have been reviewed and updated, and a review of all prior year calculations will be performed as well, to ensure compliance. Additional staff have been trained in the process, and calculations are being performed. Adequate and trained staff will ensure that all required calculations are performed accurately, and according to required timelines. In addition, the Financial Aid Office is transitioning from the SAM to the Colleague Financial Aid System (starting in 2024-25) which will provide a more automated and integrated process, with enhanced internal controls.

View Audit 300598

Finding 389690 (2023-001)

Significant Deficiency 2023

Grossmont-Cuyamaca Community College District

CA

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

These initial Pell overpayments were incurred in the “early” Pell disbursements that occurred a week before the semester started and the first two weeks of the semester. The enrollment was reported correctly, but part of the issue was the current FA system (SAM) was not programmed to adjust the amou...

These initial Pell overpayments were incurred in the “early” Pell disbursements that occurred a week before the semester started and the first two weeks of the semester. The enrollment was reported correctly, but part of the issue was the current FA system (SAM) was not programmed to adjust the amount disbursed based on the student’s current enrollment at the time of disbursement. For the Spring 2024 semester, testing will be done on SAM to disburse aid based on current enrollment for the early disbursements. If successful, this change will reduce the amount in overpayments if students drop below ½ time for the semester, or withdraw completely. In addition, the Financial Aid Office is transitioning from the SAM to the Colleague Financial Aid System (starting in 2024-25). Colleague is already programmed to disburse aid based on current enrollment status, so this will not be a recurring issue in the future. Early Disbursement and Overpayment Notes: • The 1st early Pell disbursement is based on 25% of a student’s semester award based on full-time enrollment. If a student is currently enrolled ½-time or higher when this disbursement is processed, they will receive the 25% award amount. If a student is enrolled in less than ½-time status (.5 units to 5.5 units), they will receive a $500 Pell disbursement to account for the lower semester Pell grant award for less than ½-time students. • We understand students add/drop courses through the first two weeks of the semester. The final Pell grant award for the semester is adjusted to the student’s enrollment status on Census day. Students who are ½-time or higher at Census will not be a Pell overpayment for the semester since their Pell grant award will be at 50% or higher. • For students who were enrolled at ½-time or higher at the time the early disbursement was processed, but then dropped to less than ½-time or withdrew completely by Census day, they will be considered a Pell overpayment. o These types of overpayments are unavoidable. However, we will work on minimizing the dollar amount of these types of overpayments with the actions stated above. We will test the current FA system (SAM) to disburse the early disbursements based on current enrollment status before Census and monitor closely. o Example: Currently, if a student is scheduled a $500 disbursement for the early 25% disbursement, and is enrolled ½ time, they will receive $500. With the change to actual enrollment (1/2 time for this case), the student will receive $250 instead of $500. If the student drops below ½-time or withdraws completely by census, the highest overpayment amount will be $250 instead of $500.

View Audit 300598

Finding 389662 (2023-003)

Significant Deficiency 2023

California University of Science and Medicine

CA

Special Tests & Provisions Student Financial Aid Significant Deficiency

FINDING 2023-003 – Special Tests and Provisions-Return of Title IV Funds - Significant Deficiency Over Internal Controls Over Compliance Recommendation: We recommend the University review the instructions on the form used to calculate the return of Title IV funding and update their policies and proc...

FINDING 2023-003 – Special Tests and Provisions-Return of Title IV Funds - Significant Deficiency Over Internal Controls Over Compliance Recommendation: We recommend the University review the instructions on the form used to calculate the return of Title IV funding and update their policies and procedures accordingly to ensure accurate calculations are performed. Corrective Action Plan Under the guidance of (34. CFR 668.22) (f)(2) the Office of Financial Aid will ensure to include as forementioned any consecutive breaks of five days or more to be deducted from the total days enrolled for that payment period in calculating the student earned versus unearned portion of Title IV funding when calculating a R2T4 calculation for any withdrawals, LOAs, and etc. Responsible Party Contact: Anna Cosio California University of Science and Medicine Executive Director of Financial Aid Anna.cosio@cusm.edu (909) 490 -5906 Christopher Tan California University of Science and Medicine Assistant Director of Compliance and Operations Christopher.Tan@cusm.edu (909) 566 2655 Expected date of corrective action: The corrective action will be implemented in March 2024

View Audit 300563

Finding 389661 (2023-002)

Significant Deficiency 2023

California University of Science and Medicine

CA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

FINDING 2023-002 – Special Tests and Provisions-Enrollment Reporting- Significant Deficiency Over Internal Controls Over Compliance Recommendation: We recommend the University develop additional procedures to monitor the accuracy of information reported to NSLDS. One additional monitoring control co...

FINDING 2023-002 – Special Tests and Provisions-Enrollment Reporting- Significant Deficiency Over Internal Controls Over Compliance Recommendation: We recommend the University develop additional procedures to monitor the accuracy of information reported to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate and that permanent address changes were processed. Each institution has access to correct information directly within NSLDS at any time. Corrective Action Plan: The University will contract with a third-party servicer the National Student Clearinghouse to ensure accuracy and timely reporting of the Enrollment Reporting function also known as the SSCR Report to NSLDS. The National Student Clearinghouse will work with both the Executive Director of Financial Aid and Registrar to ensure accuracy of student status reporting and dates needed for reporting (including but not limited to effective dates and graduation dates) that will be reported on behalf of the California University of Science and Medicine. In collaboration with the National Student Clearinghouse, we will change the file roster schedule to every 30 days immediately to report within the 60-day requirement as recommended. The Registrar moving forward will have access to NSLDS and receive the appropriate training on how to use NSLDS and update and enter student permanent addresses. Responsible Party Contact: Regina Maldonado National Student Clearinghouse Senior Implementation Coordinator rmaldona@studentclearinghouse.org Anna Cosio California University of Science and Medicine Executive Director of Financial Aid Anna.cosio@cusm.edu (909) 490 -5906 Don Nguyen California University of Science and Medicine Registrar Don.Nguyen@cusm.edu (909) 966- 5085 Expected date of corrective action: The corrective action will be implemented in April 2024

View Audit 300563

Finding 389659 (2023-004)

Significant Deficiency 2023

Boston Architectural College

MA

Reporting Student Financial Aid Cash Management

Corrective Action Plan The one student found with a disbursement reported late to COD was the result of a correction which was posted past the deadline. This was the result of staff turnover in the Financial Aid Office and the use of temporary employees as we began the job search for permanent repla...

Corrective Action Plan The one student found with a disbursement reported late to COD was the result of a correction which was posted past the deadline. This was the result of staff turnover in the Financial Aid Office and the use of temporary employees as we began the job search for permanent replacements. Going forward, training will be provided to all new employees including temporary employees. Timeline for Implementation of Corrective Action Plan The College plans to implement the corrective action plan by April 1, 2024. Contact Person James Ryan, Ph.D. Vice President of Enrollment Management

View Audit 300562

Finding 389658 (2023-003)

Significant Deficiency 2023

Boston Architectural College

MA

Reporting Student Financial Aid Matching / Level of Effort / Earmarking

Corrective Action Plan The Boston Architectural College recognizes the importance of complying with all federal requirements. In this case out of the sample of 40 students one student was reported late to NSLDS. This late reporting was due to human error in processing the status change internally la...

Corrective Action Plan The Boston Architectural College recognizes the importance of complying with all federal requirements. In this case out of the sample of 40 students one student was reported late to NSLDS. This late reporting was due to human error in processing the status change internally late and therefore missing the next automated upload to NSLDS. Measures will be put in place to ensure all changes are processed timely, including updating the automatic reporting to capture all potential changes. Timeline for Implementation of Corrective Action Plan The College plans to implement the corrective action plan by April 1, 2024. Contact Person James Ryan, Ph.D. Vice President of Enrollment Management

View Audit 300562

Finding 389645 (2023-005)

Significant Deficiency 2023

Felician University

NJ

Questioned Costs Student Financial Aid Significant Deficiency

Federal Supplemental Educational Opportunity Grant; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures related to Title IV outstan...

Federal Supplemental Educational Opportunity Grant; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Student Accounts initiated a thorough review with Finance and Financial Aid to ensure timely return of Title V funds to the Department of Education of uncashed refund checks exceeding 240 days. This includes documenting new procedures in our Policies and Procedures manual and providing staff training. Planned Completion Date for Corrective Action Plan: June 30th, 2024 Name(s) of the contact person(s) responsible for corrective action: Mariela Henriques, Director of Student Accounts

View Audit 300547 Questioned Costs: $1

Finding 389643 (2023-004)

Significant Deficiency 2023

Felician University

NJ

Student Financial Aid Reporting Significant Deficiency

Federal Pell Grant Program; Federal Direct Student Loans – 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 disagre...

Federal Pell Grant Program; Federal Direct Student Loans – 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: Financial Aid will update reporting procedures for COD system accuracy and timeliness, followed by comprehensive staff training on requirements and deadlines. We'll implement monitoring for closer disbursement date tracking and enhance communication channels between departments for smoother coordination. Name(s) of the contact person(s) responsible for corrective action: Kathy Prieto, Director of Financial Aid. Planned completion date for corrective action plan: June 30th, 2024

View Audit 300547

Finding 389641 (2023-003)

Material Weakness 2023

Felician University

NJ

Reporting Student Financial Aid Material Weakness

Federal Pell Grant Program; Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around reporting requirements to the NSLDS to ensure the University is in co...

Federal Pell Grant Program; Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around reporting requirements to the NSLDS to ensure the University is in compliance with enrollment reporting requirements. Action taken in response to finding: Registration and Records has implemented robust controls, policies, and procedures to ensure compliance with the requirements of the student financial assistance program. Despite challenges in working with the NSC, including occasional difficulties in understanding discrepancies in reported data, we have maintained ongoing staff training, expanded NSC reporting, improved records maintenance, and enhanced auditing and retrieval processes. Additionally, we have established a collaborative relationship with the NSC to address reporting issues promptly, although we recognize there may be instances beyond our control. Name(s) of the contact person(s) responsible for corrective action: Erminda Velez- Quinones, Director of Registration and Records. Planned completion date for corrective action plan: June 30th, 2024

View Audit 300547

Finding 389630 (2023-002)

Significant Deficiency 2023

Reinhardt University

GA

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

Finding 2023-002: Special Tests and Provisions: Enrollment Reporting Context/Condition: Of the 40 students selected for enrollment reporting testing, six (6) students within the sample were reported to NSLDS outside the maximum 60-day window and two (2) students within the sample were not reported ...

Finding 2023-002: Special Tests and Provisions: Enrollment Reporting Context/Condition: Of the 40 students selected for enrollment reporting testing, six (6) students within the sample were reported to NSLDS outside the maximum 60-day window and two (2) students within the sample were not reported to NSLDS. Recommendation: The auditor recommended that the College review and update internal controls to ensure student enrollment status in the National Student Loan Data System (NSLDS) is updated in a timely manner to ensure compliance with Federal requirements. Persons Responsible for Corrective Action: Registrar Janet Rodning Planned Corrective Action: Monthly the Registrar will audit a sample of students reported to the NSC to ensure that reporting happens within the 60-day window and will audit students’ conferrals to ensure that correct reporting is made to NSC and NSLDS. Additionally, internal control procedures will be updated to ensure timely updating of student enrollment status. Anticipated Completion Date: June 30, 2024.

View Audit 300527

Finding 389524 (2023-003)

Significant Deficiency 2023

Widener University

PA

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

2023-003 Federal Perkins Loan Program – Federal Assistance Listing Number 84.038 Recommendation: The University implement a procedure with the third-party servicer to ensure that reporting is completed timely so that the University can perform the necessary due diligence we need to perform. Expla...

2023-003 Federal Perkins Loan Program – Federal Assistance Listing Number 84.038 Recommendation: The University implement a procedure with the third-party servicer to ensure that reporting is completed timely so that the University can perform the necessary due diligence we need to perform. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Widener University will work directly with our third-party service provider to gain comfort over compliance controls. In the event of unexpected delays in procuring future years’ compliance audit reports, Widener University will undertake additional testing to ensure proper controls exist in a timely manner. William Lockard, Associate Vice President of Fiscal Operations & Risk Management is the person responsible for corrective action. Planned completion date for corrective action plan: June 30, 2024

View Audit 300486

Finding 389521 (2023-001)

Significant Deficiency 2023

Widener University

PA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

2023-001 Student Financial Assistance Cluster – Federal Assistance Listing Number 84.063, 84.268 – Enrollment Reporting Recommendation: The University review policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to...

2023-001 Student Financial Assistance Cluster – Federal Assistance Listing Number 84.063, 84.268 – Enrollment Reporting Recommendation: The University review 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: Widener University is committed to ensuring timely and accurate enrollment reporting. We will conduct a comprehensive review of the NSLDS Enrollment Reporting Guide to establish policies that comply with the enrollment reporting requirements. Colleen Shinkle, Director of Financial Aid Services, is the person responsible for corrective action. Planned completion date for corrective action plan: June 1, 2024

View Audit 300486

Finding 389516 (2023-001)

None 2023

Gannon University

PA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Finding 2023-001 Condition The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 3 students with status changes in our sample of 25 students. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: • Documen...

Finding 2023-001 Condition The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 3 students with status changes in our sample of 25 students. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: • Documentation will be updated to include the following: o Adjustment to the frequency by which reports are run. o How to handle students with a G Not Applied error from the National Student Clearinghouse. o Implications for not fixing G Not Applied records with the 60-day requirement window. • Monthly reports of graduates will be run and submitted to the National Student Clearinghouse unless there are no graduates for the reporting period. • Existing G Not applied records will be assessed and corrected as needed. • Individuals will be designated as back-ups; they will review all documentation and be trained on the procedures to ensure the appropriate actions can be sustained by the departments should there be turnover in key positions. Name(s) of Contact Person(s) Responsible for Corrective Action: 1. Megan Loibl, Registrar 2. Zachary Hopkins, Director of Institutional Research Assessment and Analytics Anticipated Completion Date: Corrective action with associated documentation will be created, tested, and confirmed that it resolves the root cause of the finding by Friday, May 31st, 2024.

View Audit 300471

Finding 389481 (2023-002)

Significant Deficiency 2023

Endicott College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding Reference 2023-002 Finding: In testing the Campus-Level enrollment reporting data elements as reported to NSLDS, key items to test are: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. In testing the Program-Level enrollment reporting data elements, key it...

Finding Reference 2023-002 Finding: In testing the Campus-Level enrollment reporting data elements as reported to NSLDS, key items to test are: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. In testing the Program-Level enrollment reporting data elements, key items to test, if applicable, are: OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. Of the 40 students with enrollment changes that we selected for testwork, we identified 13 students whose changes in enrollment status were not timely or accurately transmitted to NSLDS, as follows: • KPMG identified that 9 students had enrollment statuses that did not agree between campus-level and program-level NSLDS data. • KPMG identified that 2 students had Program Enrollment Effective Dates that did not agree the College’s records. • KPMG identified that 2 students had status changes that were reported to NSLDS more than 60 days after the date that the College became aware of the changes. None of the items that were exceptions described above resulted in changes to the amounts awarded or disbursed to students by the College for the current fiscal year. Endicott College Responsible Contact: Karen Loomer, Registrar, Corrective Action Plan: The issues caused by the current processes and the following action has been taken to improve the situation. Endicott will review and enhance its process related to enrollment reporting. To that end, the Registrar’s Office has reviewed all reports being used to gather enrollment reporting information and has created new reports to ensure that both the campus level and program level data are being reported correctly and within appropriate time controls. Anticipated Completion Date: February 2024

View Audit 300451

Finding 389480 (2023-001)

Significant Deficiency 2023

Endicott College

MA

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

Finding Reference: 2023-001 Finding: During testing of student loan notifications, it was identified that one of forty students selected for test work did not receive a notification for three loan disbursements during the year. The item that was an exception described above did not result in changes...

Finding Reference: 2023-001 Finding: During testing of student loan notifications, it was identified that one of forty students selected for test work did not receive a notification for three loan disbursements during the year. The item that was an exception described above did not result in changes to the amounts awarded or disbursed to students by the College for the current fiscal year. The condition identified was the result of a student that selected to opt-out of College email notifications, which resulted in federal loan notifications to not be delivered. The College did not have adequate processes in place to ensure appropriately notification in accordance with federal regulations when a student selected to opt-out of receiving College communications. Endicott College Responsible Contact: Bryan Cain, Senior VP for Student and External Engagement Corrective Action Plan: This finding was the result of students being allowed to opt out of all notifications from Endicott College, which are initiated thru a notification system called EMMA. EMMA is the system of record used for notifying students of loan disbursements and as a result of students being able to opt out of all EMMA notifications this student was not notified of their loan disbursements. As a result of this finding the college has disabled the ability for students to be able to opt out of all EMMA notifications and thus being unable to opt out of student financial notifications such as loan disbursements. Anticipated Completion Date: February 2024

View Audit 300451

Finding 389387 (2023-007)

Significant Deficiency 2023

Urshan College

MO

Special Tests & Provisions Student Financial Aid Period of Performance

2023-007 Special Tests and Provisions – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagr...

2023-007 Special Tests and Provisions – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The director of financial aid works with the third-party servicer to ensure accurate student programs and program beginning dates reported to NSLDS. The financial aid office cross references program information within the student information system. Name(s) of the contact person(s) responsible for corrective action: Jason Benavides, Interim Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025

View Audit 300370

Finding 389385 (2023-006)

Significant Deficiency 2023

Urshan College

MO

Matching / Level of Effort / Earmarking Special Tests & Provisions Student Financial Aid § 200.303

2023-006 Special Tests and Provisions – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagr...

2023-006 Special Tests and Provisions – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The director of financial aid works with the third-party servicer to ensure accurate and timely enrollment updates to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Jason Benavides, Interim Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025

View Audit 300370

Finding 389383 (2023-005)

Significant Deficiency 2023

Urshan College

MO

Student Financial Aid Procurement, Suspension & Debarment Internal Control / Segregation of Duties

2023-005 Eligibility – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the a...

2023-005 Eligibility – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office designed a new process to coordinate with the academic office to review SAP status of students and ensure appropriate letters will be sent. Name(s) of the contact person(s) responsible for corrective action: Jason Benavides, Interim Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025

View Audit 300370

Finding 389382 (2023-004)

Significant Deficiency 2023

Urshan College

MO

Student Financial Aid Eligibility Reporting

2023-004 Eligibility – Assistance Listing No. 84.063 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to findi...

2023-004 Eligibility – Assistance Listing No. 84.063 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The director of financial aid works with the third-party servicer to ensure accurate and timely disbursement dates to COD. Name(s) of the contact person(s) responsible for corrective action: Jason Benavides, Interim Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025.

View Audit 300370

Finding 389378 (2023-006)

Significant Deficiency 2023

South Carolina State University

SC

Student Financial Aid Reporting Internal Control / Segregation of Duties

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in t...

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations. In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department. The University’s failure to reconcile the Fiscal Operations Report and Application to Participate to supporting documentation will be assessed by the new internal audit team. Corrective procedures and additional internal controls to ensure compliance with the special reporting requirements will be developed and/or modified as necessary. In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls to ensure compliance with the special reporting requirements. Anticipated Completion Date: June 30, 2024

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Finding 389377 (2023-005)

Significant Deficiency 2023

South Carolina State University

SC

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

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in t...

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations. The University’s inability to provide evidence that a student’s Perkins Loan repayment schedule and another student’s Perkins Loan file were retained as required will be assessed by the new internal audit team. Corrective procedures and additional internal controls to ensure compliance with the special reporting requirements will be developed. In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls to ensure compliance with the special reporting requirements. Anticipated Completion Date: June 30, 2024

View Audit 300369

Finding 389367 (2023-002)

Significant Deficiency 2023

South Carolina State University

SC

Student Financial Aid Special Tests & Provisions Reporting

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in t...

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations. Management and implementation of current corrective plans are critical to the compliance efforts of the University: As stated in the previous corrective action plan the Registrar’s Office in coordination with the Information Technology Division has developed a “flag based” process to capture and monitor enrollment status changes. The implementation and proper reporting of these activities will be led the applicable team with oversight and assistance from the new internal auditing team. As this is a repeated finding, the University‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance/operation offices (Registrar’s Office and Academic Affairs Office). The University is requesting a report be filed on the status of this reporting requirement on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle. In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the applicable compliance requirements of enrollment reporting to ensure that all status changes are submitted to NSLDS within the required timeframe. Anticipated Completion Date: June 30, 2024

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Corrective Action Plans

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