Corrective Action Plans

Finding 10428 (2023-001)

Significant Deficiency 2023

CA

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

2023-001: Student Eligibility and Awarding Recommendation: We recommend the District to evaluate its procedures related to the manual input of information from the student loan request. Action taken in response to finding: This issue was the result of using the Solano completed unit level, rather th...

2023-001: Student Eligibility and Awarding Recommendation: We recommend the District to evaluate its procedures related to the manual input of information from the student loan request. Action taken in response to finding: This issue was the result of using the Solano completed unit level, rather than the cumulative number that includes transfer units, when awarding a student in our small BS Biotechnology program. Student had completed 43.5 credits at Solano by the beginning of the aid year. As a result, the student was awarded a second-year subsidized amount when they were eligible for the third year and beyond amount. This resulted in the student receiving $1,000 less subsidized loans than they were eligible for. In July 2023, we trained the team to watch for this issue and evaluated the procedure log that we use for processing Direct Loans. This log now includes two checks that are relevant to ensuring subsidized loan amounts are correct: 1. Confirm the level of the student. If the student is in our BS Biotechnology program, they may have additional eligibility than the standard first-year and second-year loans that we normally process as a community college. 2. If the loan is a single-term loan, is the full subsidized eligibility exhausted before awarding any unsubsidized loan amounts? The student’s file was corrected on COD on 8/3/2023 to reflect a $5,500 subsidized award. Names of the contact persons responsible for corrective action: Patrick Scott, Dean – Financial Aid, and Kate Larot, Financial Aid Specialist Planned completion date for corrective action plan: August 2023

View Audit 14106 Questioned Costs: $1

Finding 10400 (2023-001)

Significant Deficiency 2023

College of Dupage Community College District 502

IL

Student Financial Aid Reporting Significant Deficiency

U.S. Department of Education College of DuPage, Community College District Number 502 (the College), respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: CliftonLarsonAllen LLP, Oak Brook, Illinois Audi...

U.S. Department of Education College of DuPage, Community College District Number 502 (the College), respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: CliftonLarsonAllen LLP, Oak Brook, Illinois Audit period: July 1, 2022 – June 30, 2023 The findings from the schedule of findings, responses, and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings – Financial Statement Audit: None Findings – Federal Award Programs Audits: Department of Education 2023‐001 – Enrollment Status Reporting Recommendation: We recommend that the College review its procedures to ensure enrollment status changes are reported to NSLDS accurately, as required by regulations. Planned Corrective Action: The College of DuPage has reviewed and agrees with the enrollment reporting finding. The College has already taken multiple steps to resolve all issues ensuring complete, accurate and timely reporting. However, all those steps have not fully resolved the issue with enrollment reporting. As such, we will be working on a long‐term system improvement with the goal of limiting issues and future audit findings. The Financial Aid Office and the Registrar’s Office will work closely with the Information Technology department to automate a process of capturing unofficial withdrawal information, using the NSLDS template and then uploading that report directly to NSLDS on a weekly basis. The College will continue to send records to the National Student Clearinghouse and use this new report to supplement reporting and resolve the issues with reporting unofficial withdrawals. The goal is to implement this new report by June 30, 2024. Contacts Responsible for Corrective Action: Dr. Diana Del Rosario, Assistant Provost, Student Affairs Jill Pierson, Registrar Scott Brady, CFO & Treasurer Anticipated Completion Date: June 30, 2024 If the U.S. Department of Education has questions regarding this plan, please do not hesitate to call me at (630) 942‐2219.

View Audit 14059

Finding 10386 (2023-001)

Significant Deficiency 2023

Palmerton Area School District

PA

Reporting Student Financial Aid

Moving forward, we will implement procedures and develop oversight to ensure reports are filed in a timely manner.

View Audit 14048

Finding 10356 (2023-007)

Significant Deficiency 2023

Clatsop Community College

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the college implement procedures to ensure direct loan reconciliations are performed monthly and reviewed by someone other than the preparer. Explanation of disagreement with audit finding: There is no...

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the college implement procedures to ensure direct loan reconciliations are performed monthly and reviewed by someone other than the preparer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office is aware of the requirement to perform direct loan reconciliation. We are now appropriately staffed with monthly reconciliation being performed by the Assistant Director and being sent to the Director of Accounting for review. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse & Layla Solar Planned completion date for corrective action plan: Completed

View Audit 14009

Finding 10352 (2023-006)

Significant Deficiency 2023

Clatsop Community College

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for Third Party Servicers are being met. Explanation of disagreement with audit finding: Th...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for Third Party Servicers are being met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The links to the BankMobile contract and costs have been posted on the College web page that explains student stipends and the College use of Bank Mobile to provide these stipends. The links have been given to the College Financial Aid Director to upload to the US Dept of Education. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Completed

View Audit 14009

Finding 10348 (2023-005)

Material Weakness 2023

Clatsop Community College

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College draft and implement IT policies and create an updated WISP to ensure the College is compliant with the GLBG Safeguards Rule. Explanation of disagreement with audit ...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College draft and implement IT policies and create an updated WISP to ensure the College is compliant with the GLBG Safeguards Rule. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clatsop Community College is working on its information security plan, as well as vendor and change management plans. The plans will be presented to College Council in spring 2024 before they are finalized. Name(s) of the contact person(s) responsible for corrective action: Greg Riehl Planned completion date for corrective action plan: June 30, 2024

View Audit 14009

Finding 10344 (2023-004)

Material Weakness 2023

Clatsop Community College

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Explanation of disagreement with audit finding: There i...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The college will create a stronger infrastructure around records and reporting by reducing the number of staff who have access to student coding. The number of staff allowed access to student program changes and enrollment transactions results in a significant number of errors on the NSC report due to effective dating issues. The volume of errors is not manageable with the current staff and will continue to be so regardless of additional infrastructure if changes in the business process are not implemented. The Registrar is creating a system for effective dating and reducing the number of employees with access to student program coding and enrollment transactions as part of the implementation of the new ERP system Colleague. In addition, the Registrar will create a student coding and effective dating chart that outlines the dates and deadlines associated with allowable student program changes and enrollment transactions. The reduction in staff access and implementation of effective dating in alignment with the new enterprise system Colleague and NSC reporting requirements will result in compliance with NSLDS reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Siv Barnum Planned completion date for corrective action plan: FY2024-25

View Audit 14009

Finding 10343 (2023-003)

Significant Deficiency 2023

Clatsop Community College

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend that the College review their awarding procedures and implement procedures to ensure direct loans are paid within the aggregate limits. Explanation of disagreement with audit finding: There is no disag...

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend that the College review their awarding procedures and implement procedures to ensure direct loans are paid within the aggregate limits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office is now appropriately staffed and extra time will be taken to ensure NSLDS is being reviewed prior to loan origination. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleysne & Layla Solar Planned completion date for corrective action plan: Completed

View Audit 14009

Finding 10342 (2023-002)

Significant Deficiency 2023

Clatsop Community College

OR

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

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

Student Financial Aid Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to 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: The financial aid office and student accounts office will work together to clearly communicate the timing of aid being applied to student accounts and being reported to COD to ensure both actions are happening on the same day. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Completed

View Audit 14009

Finding 10322 (2023-001)

Significant Deficiency 2023

Illinois Central College District 514

IL

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

The College meets or exceeds the system and data security requirements as stipulated in the GLBA and best industry practice and standards for IT system security. There are no identified weaknesses or concerns for the security of College data. Formal documentation of procedures and process are in pl...

The College meets or exceeds the system and data security requirements as stipulated in the GLBA and best industry practice and standards for IT system security. There are no identified weaknesses or concerns for the security of College data. Formal documentation of procedures and process are in place and being formalized by the Institution and the College will be in compliance with the requirement for formal written standards going forward.

View Audit 13983

Finding 10287 (2023-002)

Significant Deficiency 2023

Laramie County Community College

WY

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility

Corrective Action: The College’s Return of Title IV Funds procedure was reviewed. The following language was revised in the post-withdrawal disbursement (PWD) section of this procedure as a control to ensure that advanced written notification is not missed in the future: A written notification will...

Corrective Action: The College’s Return of Title IV Funds procedure was reviewed. The following language was revised in the post-withdrawal disbursement (PWD) section of this procedure as a control to ensure that advanced written notification is not missed in the future: A written notification will be sent to a student (or parent) that is eligible for a PWD of Federal Direct Loan within 30 days of the date of determination. The type and amount of Title IV loan funds that will be credited to the student’s charges and the amount that will directly disburse will be offered to the student, or the parent in the case of a PLUS Loan. The notification will explain that the student or parent can accept all or part of the loan disbursement and will advise the student or parent that no post-withdrawal disbursement of Title IV loan funds will be made unless the school receives a confirmation response within the established timeframe of 14 days. Please note that loan PWDs are very rare at the College because the vast majority of our students that wish to borrow complete their loan requirements and receive their loan disbursement prior to their withdrawal date. In the case of the student noted in the finding, the student completed his loan requirements (i.e., master promissory note and loan entrance counseling) only a couple of days before the date he became ineligible. We acknowledge an advanced written notice was not sent, but please note that a written notification was sent to the student immediately following the loan disbursement informing the student about his right to cancel all or part of the loan and the procedures and timeframe in which to do so. Anticipated Completion Date: July 1, 2023 Contact Person: Brandi Payne Cervera

View Audit 13927

Finding 10272 (2023-004)

Significant Deficiency 2023

Western Wyoming Community College

WY

Student Financial Aid

WWCC cannot confirm that the Bank Mobile contract was provided to the Department of Education (ED) as required due to staff turnover. However, WWCC has ended the contract with Bank Mobile and beginning with the Spring 2024 semester, credit balance refunds will be issued by EFT using bank account inf...

WWCC cannot confirm that the Bank Mobile contract was provided to the Department of Education (ED) as required due to staff turnover. However, WWCC has ended the contract with Bank Mobile and beginning with the Spring 2024 semester, credit balance refunds will be issued by EFT using bank account information provided by the student or by check issued by WWCC if the student does not provide a bank account in TouchNet. TouchNet does not open any accounts or offer any debit cards to issue credit balance refunds to WWCC students. WWCC will ensure that all ED reporting requirements are met for the Touchnet contract. Anticipated Completion Date: December 31, 2023 Contact Person: Amy Murphy, Dean of Outreach and Workforce Development & Interim Dean of Enrollment Management

View Audit 13919

Finding 10271 (2023-003)

Significant Deficiency 2023

Western Wyoming Community College

WY

Student Financial Aid Eligibility Reporting

Prior to the 2023-2024 academic year, the Registrar has completed several trainings regarding reporting and has developed and implemented a schedule to ensure timely and accurate reporting to National Student Clearinghouse as well as resolving any errors in a timely manner. As of the 2023-2024 acade...

Prior to the 2023-2024 academic year, the Registrar has completed several trainings regarding reporting and has developed and implemented a schedule to ensure timely and accurate reporting to National Student Clearinghouse as well as resolving any errors in a timely manner. As of the 2023-2024 academic year, this institution is reporting withdraw dates and student status changes accurately. Through research and training, the program length is currently being updated to reflect 2 years or 4 years rather than reporting in months. This reporting change was put into place prior to the final submission of 2023 Fall. Anticipated Completion Date: December 31, 2023 Contact Person: Amy Murphy, Dean of Outreach and Workforce Development & Interim Dean of Enrollment Management

View Audit 13919

Finding 10269 (2023-001)

Significant Deficiency 2023

Western Wyoming Community College

WY

Questioned Costs Student Financial Aid Eligibility

Pell This finding is the result of manual awarding and revisions by staff that are no longer employed by WWCC. To prevent Pell underpayment, Colleague was reconfigured for 2023-2024 to accurately award and revise awards when students add courses prior to the census date. Additionally, a regular revi...

Pell This finding is the result of manual awarding and revisions by staff that are no longer employed by WWCC. To prevent Pell underpayment, Colleague was reconfigured for 2023-2024 to accurately award and revise awards when students add courses prior to the census date. Additionally, a regular review of the Pell Eligibility Variance Report in Colleague (which displays students with a Colleague calculated Pell that differs from what the student has been awarded) will identify any student not awarded to their full Pell eligibility. Loan This finding is the result of a miscalculation of single term costs of attendances (COA) for students enrolling spring only. To address the 2022-2023 overpayments identified, all students enrolled for the spring single term while receiving Title IV funding had their COA recalculated, financial need determined using the four (4) month EFC, and SEOG, and subsidized/unsubsidized loan eligibility recalculated. Where required, the SEOG, and subsidized/unsubsidized loans were adjusted to actual eligibility and the student account and COD updated. Documentation that this action was completed has been provided to the auditor. For 2023-2024, Colleague was reconfigured to calculate COA components at a per term level, instead of at an annual level (which was used in 2022-2023). Colleague was also reconfigured to calculate the EFC for a single term student so that the financial need could be determined correctly. As a result, single term students will receive a single term COA and EFC to accurately the student’s financial need. SEOG and subsidized/unsubsidized loans will be awarded based on financial need and remaining costs. Anticipated Completion Date: December 31, 2023 Contact Person: Amy Murphy, Dean of Outreach and Workforce Development & Interim Dean of Enrollment Management

View Audit 13919 Questioned Costs: $1

Finding 10259 (2023-010)

Significant Deficiency 2023

Heritage University

WA

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

2023-010 – Special Tests and Provisions – Federal Perkins Loan Liquidation – Significant Deficiency in Internal Controls over Compliance Recommendation: The auditors recommend the University reconcile the information to the most recent filed FISAP to ensure the entire portfolio of Perkins loans wa...

2023-010 – Special Tests and Provisions – Federal Perkins Loan Liquidation – Significant Deficiency in Internal Controls over Compliance Recommendation: The auditors recommend the University reconcile the information to the most recent filed FISAP to ensure the entire portfolio of Perkins loans was properly liquidated. Planned corrective actions: To ensure the Perkins loan portfolio was correctly liquidated, the University will reconcile the data with the most current FISAP filed. Name of Responsible Party: 1. Financial Aid Director 2. Alysia Stevens, Controller 3. VP of Administration/CFO 4. Dr. Andrew Sund, President Anticipated completion date: 6/30/2024

View Audit 13897

Finding 10253 (2023-009)

Significant Deficiency 2023

Heritage University

WA

Questioned Costs Student Financial Aid Special Tests & Provisions

2023-009 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Significant Deficiency in Internal Controls over Compliance Recommendation: The auditors recommend the University review their policies and procedures to ensure that all withdrawals have the appropriate documentation to su...

2023-009 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Significant Deficiency in Internal Controls over Compliance Recommendation: The auditors recommend the University review their policies and procedures to ensure that all withdrawals have the appropriate documentation to support the withdrawal date used in the calculation. Planned corrective actions: In order to make sure that all withdrawals have the proper evidence to support the withdrawal date used in the computation, the University will evaluate its rules and procedures. Name of Responsible Party: 1. Mary Neal, Registrar 2. Financial Aid Director 3. Melissa Hill, Provost 4. VP of Administration/CFO 5. Dr. Andrew Sund, President Anticipated completion date: 6/30/2024

View Audit 13897 Questioned Costs: $1

Finding 10248 (2023-007)

Significant Deficiency 2023

Heritage University

WA

Student Financial Aid Reporting Subrecipient Monitoring

2023-007 – Special Tests and Provisions - Enrollment Reporting – Significant Deficiency in Internal Controls over Compliance Recommendation: The auditors recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accu...

2023-007 – Special Tests and Provisions - Enrollment Reporting – Significant Deficiency in Internal Controls over Compliance Recommendation: The auditors recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. The auditors also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions. Planned corrective actions: The University will adhere to current regulations and improve them if necessary to guarantee that all student status changes are recognized promptly and filed correctly within the allotted period. In order to internally audit the National Student Clearinghouse submissions, the University established a formal internal monitoring system wherein a designated individual with NSLDS access, on a sample basis, spot-checks the status updates on NSLDS. Name of Responsible Party: 1. Mary Neal, Registrar 2. Financial Aid Director 3. Melissa Hill, Provost 4. VP of Administration/CFO 5. Dr. Andrew Sund, President Anticipated completion date: 6/30/2024

View Audit 13897

Finding 9990 (2023-001)

Material Weakness 2023

College of Southern Idaho

ID

Special Tests & Provisions Student Financial Aid Material Weakness

Finding: 2023-001 Federal Agency Name: Department of Education Program Name: Student Financial Assistance Cluster ALN #: 84.007, 84.033, 84.063, and 84.268 Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a stu...

Finding: 2023-001 Federal Agency Name: Department of Education Program Name: Student Financial Assistance Cluster ALN #: 84.007, 84.033, 84.063, and 84.268 Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student's enrollment status and changes in those enrollment statuses, whether they report directly or via a third-party servicer. When an Institution is made aware of a change in a student's enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS. During the testing of compliance for Enrollment Reporting, there were six instances out of 29 where CSI did not report a student's change in enrollment status accurately or within the required time frame of 60 days from the effective date of the student's change in enrollment status. Responsible Individuals: Bethany Parmer, Registrar and Larisa Alexander Information Technology Corrective Action Plan: The Office of the Registrar and Information Technology team is currently working with the Student Information System support to determine the cause of an issue with the National Student Clearinghouse reporting related to the graduated status. The Office of the Registrar will be ensuring these graduated statuses are entered manually to NSC/NSLDS within the 60 days of completion until the reporting issue is resolved. Anticipated Completion Date: January 12, 2024

View Audit 13633

Finding 9981 (2023-001)

Significant Deficiency 2023

Harford Community College

MD

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

U.S. Department of Education 2023-001: Special Tests and Provisions - National Student Loan Data System (NSLDS) Reporting Condition: Student’s change in enrollment status was not properly reported to National Student Loan Data System (NSLDS). Recommendation: We recommend the College review its repor...

U.S. Department of Education 2023-001: Special Tests and Provisions - National Student Loan Data System (NSLDS) Reporting Condition: Student’s change in enrollment status was not properly reported to National Student Loan Data System (NSLDS). Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses and enrollment information are correctly and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College worked with the National Student Clearinghouse (NSC) to correct and update the students’ statuses to graduation. Per the recommendation of the NSC Audit Resource Division, the College will now add an additional graduate only file to the enrollment verify file and submit the degree verify file after the enrollment graduate file had been submitted. After these reports are run any students who are still being put on the graduate not applied list will be manually updated by the Registrar Office. Name of the contact person responsible for corrective action: Courtney Mitchell, Registrar Planned completion date for corrective action plan: November 30, 2023

View Audit 13614

Finding 9921 (2023-002)

Significant Deficiency 2023

Florida Southern College

FL

Student Financial Aid Reporting Significant Deficiency

Enrollment Reporting Recommendation: We recommend that the College review and implement procedures to ensure the correct date and status is reported to the NSLDS in all cases. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response...

Enrollment Reporting Recommendation: We recommend that the College review and implement procedures to ensure the correct date and status is reported to the NSLDS in all cases. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: For the two students who were dual degree, manual entry errors were the cause and were corrected. The College will implement a process in September 2023 where a second reviewer from Institutional Research will review the manual entry for student status changes to ensure that the correct dates are reported to NSDLS. For the third student, the timing of the notification of withdrawal, which had to be processed retroactively, and when the certification file was sent to NSDLS caused the student to be left out of the certification file. The College has added additional College officials (in Institutional Research) to the daily and monthly withdrawal lists so students who are processed retroactively will not be missed. Name(s) of the contact person(s) responsible for corrective action: Lindsay Thibodaux Planned completion date for corrective action plan: September 2023

View Audit 13554

Finding 9919 (2023-001)

Significant Deficiency 2023

Florida Southern College

FL

Questioned Costs Student Financial Aid Significant Deficiency

2023-001 Return to Title IV Recommendation: We recommend that the College review and implement procedures to ensure that withdrawals are properly communicated to all departments and processed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. ...

2023-001 Return to Title IV Recommendation: We recommend that the College review and implement procedures to ensure that withdrawals are properly communicated to all departments and processed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will implement a plan to require faculty to update the last date of attendance at the end of the term in the portal for students attending distance learning classes. This date will be used by the Registrar’s Office and Financial Aid Office for reporting. Name(s) of the contact person(s) responsible for corrective action: Dr. Tracy Tedder Planned completion date for corrective action plan: August 2023

View Audit 13554 Questioned Costs: $1

Finding 9884 (2023-003)

None 2023

Millikin University

IL

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

2023-003 – Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program – Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for Coll...

2023-003 – Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program – Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: During our testing of forty individuals receiving federal work study, we noted 2 individuals (5%) that either had timecards for hours worked that were not approved by a supervisor or had incorrect time entry. We consider this condition to be an instance of noncompliance relating to the Activities Allowed or Unallowed compliance requirement. Statistical sampling was not used in making sample selections. Management Response: There were 2 individuals improperly paid. In the first incident an electronic student timecard was submitted in error and not approved by the supervisor. The payroll administrator erroneously paid the employee for the time in the amount of $82 without supervisor approval. In the second incident the employee submitted a manual timecard with the incorrect number of hours indicated per shift. The supervisor and the payroll administrator both missed the incorrect calculation in the amount of $72. Corrective Action Plan: The University has implemented electronic timecards that will mitigate manual errors in calculation. A new payroll administrator has been hired and the University is focused on documentation of student-payroll procedures and supervisor training. Responsible Person: Student Payroll Accounting Specialist Implementation Date: September 5, 2023.

View Audit 13525 Questioned Costs: $1

Finding 9883 (2023-002)

None 2023

Millikin University

IL

Questioned Costs Student Financial Aid Special Tests & Provisions

2023-002 – Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program – Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for Coll...

2023-002 – Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program – Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: The University did not properly calculate the refunds for no passing grades withdrawal students for 1 out of the 16 students tested (6.3%) due to excluding SEOG Grant from the calculation. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used. Management Response: Student Identifier 6 - The student was identified after the conclusion of the term to have earned no passing grades and a determination was made as to when the student stopped attending classes for the term. The determined last date of attendance required a manual return of Title IV funds to be calculated. The calculation and subsequent return of funds was performed timely, however, an SEOG award of $250 was not included in error when the calculation was made. Corrective Action Plan: Student Identifier 6 - When notified of the finding by auditors, the return of Title IV funds calculation was performed with the $250 SEOG funds included. The corrected calculation resulted in an additional $127 in PELL grant funds to return. The return was corrected and completed on October 12, 2023. A secondary review of all manual Return of Title IV calculations has been implemented to mitigate manual errors. Responsible Person: Director, Student Financial Services Implementation Date: Fall 2023 term.

View Audit 13525 Questioned Costs: $1

Finding 9882 (2023-001)

None 2023

Millikin University

IL

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking

2023-001 – Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program – Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for Coll...

2023-001 – Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program – Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: In two of the 40 student files tested (5%), Subsidized and Unsubsidized Direct loans we not properly awarded. The University over awarded one student by $500 in Unsubsidized loans. Another student was under awarded $938 in Subsidized loans and under awarded $562 in Unsubsidized loans. Management Response: Student Identifier 22 - The student's loan limits were determined automatically by our student information system during the awarding process expecting the student to successfully complete the hours in which they were enrolled and progress to the next class level for the subsequent term. The student failed one course and missed progressing to the next academic level. When the manual adjustment was made to the student's awarded loan amounts after the end of the term, the subsidized loan was adjusted and the unsubsidized loan was missed, causing the over-award of $500 for one term. Student Identifier 23 - A pro-ration of loan limits was required for this student due to graduation at mid-term. Instead of using the full annual loan limit to calculate the pro-rated amount, the remaining aggregate eligibility was used as the amount from which the pro-ration was calculated. The manual mis-calculation resulted in the student being offered $938 less Subsidized loan and $562 less in Unsubsidized loan funds than they were eligible to receive. Corrective Action Plan: Student Identifier 22 - The $500 unsubsidized direct loan over payment was corrected and returned on July 31, 2023. Student Identifier 23 - The miscalculation of total loan eligibility was realized after the payment period ended and the student had completed their program of study/graduated with a zero account balance. No additional loan eligibility was offered. Additional staff has been trained to provide secondary verification of revised and pro-rated loan calculations. Responsible Person: Director, Student Financial Services Asst. Director/Loan Coordinator, Student Financial Services Implementation Date: Fall 2023 academic term.

View Audit 13525

Finding 9715 (2023-002)

Significant Deficiency 2023

The Corporation of Haverford College

PA

Questioned Costs Student Financial Aid Significant Deficiency

2023-002 – Federal Work Study (FWS) Over Award – Federal Assistance Listing No. 84.033 Recommendation: We recommend the College review its policies and procedures when packaging students for FWS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actio...

2023-002 – Federal Work Study (FWS) Over Award – Federal Assistance Listing No. 84.033 Recommendation: We recommend the College review its policies and procedures when packaging students for FWS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Financial Aid Office acknowledges that three students on the preliminary list of Title IV recipients provided to the auditors reflected an over-award based on the inclusion of FWS funds in their packages. All students are initially packaged through automated packaging, with the College’s software preventing over-awards. However, many awards are adjusted during the course of an academic year, and when this happens, the software’s checks no longer operate. To ensure compliance, the Financial Aid Office conducts ongoing audits throughout the year and a final audit at the end of each year, which also incorporates a final reconciliation of the FWS program. This year, the FWS/final audit was not completed before the preliminary list was submitted to the auditors. Had the audit been completed on time, the three students would not have shown as over-awards, nor would they be counted as FWS recipients. Corrective Action Plan The Financial Aid Office already audits financial aid packages to prevent over-awards. The office will ensure that such audits are completed in a timelier fashion, resulting in a proper final list of Title IV recipients to be submitted for audit review. Name(s) of the contact person(s) responsible for corrective action: Michael Colahan, Student Financial Aid Director Planned completion date for corrective action plan: Effective November 2023

View Audit 13479 Questioned Costs: $1

Corrective Action Plans

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