Corrective Action Plans

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A: COMMENTS ON FINDING AND RECOMMENDATION(S): VALOR CHRISTIAN COLLEGE OCCURS WITH THE FINDING B: ACTIONS TAKEN OR PLANNED: VALOR COLLEGE HAS IMPLEMENTED A POLICY THAT WILL INCREASE AWARENESS OF STUDENTS WHO STOP ATTENDING THEIR COURSES. THEY POLICY CONTAINS TIGHTER RESTRICTIONS ON THE TRACKING OF AT...
A: COMMENTS ON FINDING AND RECOMMENDATION(S): VALOR CHRISTIAN COLLEGE OCCURS WITH THE FINDING B: ACTIONS TAKEN OR PLANNED: VALOR COLLEGE HAS IMPLEMENTED A POLICY THAT WILL INCREASE AWARENESS OF STUDENTS WHO STOP ATTENDING THEIR COURSES. THEY POLICY CONTAINS TIGHTER RESTRICTIONS ON THE TRACKING OF ATTENDANCE AND WITHDRAWAL OF STUDENTS WHO FAIL TO PARTICIPATE. IN ADDITION, CAMPUS IVY HAS SCHEDULED A WEEKLY REVIEW OF RETURN OF TITLE IV FORMS TO ENSURE REFUNDS AND POST WITHDRAWAL DISBURSEMENTS ARE SCHEDULED IN A TIMELY MANNER.
View Audit 299675 Questioned Costs: $1
A: COMMENTS ON FINDING AND RECOMMENDATION(S): VALOR CHRISTIAN COLLEGE OCCURS WITH THE FINDING B: ACTIONS TAKEN OR PLANNED: VALOR COLLEGE WILL INCREASE CONTROLS OVER INADVERTENT OVERPAYMENTS CREATED WHEN A STUDENT WITHDRAWS WITHOUT NOTIFICATION AFTER THE FUNDS HAVE BEEN ORDERED BUT BEFORE THEY DISBUR...
A: COMMENTS ON FINDING AND RECOMMENDATION(S): VALOR CHRISTIAN COLLEGE OCCURS WITH THE FINDING B: ACTIONS TAKEN OR PLANNED: VALOR COLLEGE WILL INCREASE CONTROLS OVER INADVERTENT OVERPAYMENTS CREATED WHEN A STUDENT WITHDRAWS WITHOUT NOTIFICATION AFTER THE FUNDS HAVE BEEN ORDERED BUT BEFORE THEY DISBURSE. VALOR COLLEGE HAS REFUNDED $1,048 DUE FOR THE INCORRECT REFUNDS. FOR THE R2T4, CAMPUS IVY HAS ADDED A SECOND LAYER OF REVIEW TO THE R2T4 PROCESS. THE CURRENT CAMPUS IVY POLICY IS TO REQUIRE THE CLIENT TO SUBMIT A REFUND REQUEST FORM FOR ANY INELIGIBLE FUNDS THAT WERE DISBURSED, ALONG WITH THE R2T4. IF THE STUDENT IS THEN DUE A PWD, THE FUNDS WOULD THEN BE RESCHEDULED BASED ON THE R2T4 AND OFFERED TO THE STUDENT. THIS WILL PREVENT THE RETENTION OF INELIGIBLE FUNDS.
View Audit 299675 Questioned Costs: $1
Correction Action Plan: The University plans to implement the following: During the 2023-2024 academic year, the Registrar Office implemented the following mechanisms to ensure that all status change records are reported to NLSDS accurately.  Reinforce and train individuals in the compliance and co...
Correction Action Plan: The University plans to implement the following: During the 2023-2024 academic year, the Registrar Office implemented the following mechanisms to ensure that all status change records are reported to NLSDS accurately.  Reinforce and train individuals in the compliance and control ownership role to ensure controls are operating as designed.  Incorporate the review of student status change records within the duties of the individuals in compliance and control ownership roles within the Registrar office.
The college will implement a two-step process to verify the FWS earnings reported on the FISAP. The Financial Aid Director and Manager of Compliance will develop a checklist to include verifying payroll records/reports. The checklist will be reviewed to confirm the accuracy of data reported on the F...
The college will implement a two-step process to verify the FWS earnings reported on the FISAP. The Financial Aid Director and Manager of Compliance will develop a checklist to include verifying payroll records/reports. The checklist will be reviewed to confirm the accuracy of data reported on the FISAP. Contact person(s) responsible for corrective action: Yvette McGee, Director of Financial Aid Anticipated Completion Date: August 30, 2024
Contact Person: Carla Maria Ratico, Registrar Corrective Action: With regards to Error #2023-007, some of the findings were related to incorrect reporting of graduation status, graduation date, and program begin date. We identified that some dates had not been correctly entered. We are working with ...
Contact Person: Carla Maria Ratico, Registrar Corrective Action: With regards to Error #2023-007, some of the findings were related to incorrect reporting of graduation status, graduation date, and program begin date. We identified that some dates had not been correctly entered. We are working with our student information system software consultants and National Student Clearinghouse personnel to ensure that all staff understand reporting requirements, and we have taken steps to correct errors before we submit reports. Another finding was that error records were not corrected within the required timeframe. There has been a change in staffing in the office since the time periods of the audit findings, so a different person is now correcting error records. That individual has been made aware of the audit findings and has committed to work with office personnel and National Student Clearinghouse on correcting reported errors promptly. Anticipated Completion Date: October 1, 2024
Contact Person: Cynthia McCarthy, Director of Financial Aid Corrective Action: The issue has been addressed and reviewed. Going forward the Director of Financial Aid will set up and review all periods of enrollment and dates in the return of funds calculation on COD prior to the start of the academi...
Contact Person: Cynthia McCarthy, Director of Financial Aid Corrective Action: The issue has been addressed and reviewed. Going forward the Director of Financial Aid will set up and review all periods of enrollment and dates in the return of funds calculation on COD prior to the start of the academic year. Anticipated Completion Date: January 3, 2024
Contact Person: Cynthia McCarthy, Director of Financial Aid Corrective Action: Corrections to the FISAP were made prior to the correction submission deadline date. A review in the Detail Reporting process in Powerfaids was conducted and determined that the process in Powerfaids initially reported th...
Contact Person: Cynthia McCarthy, Director of Financial Aid Corrective Action: Corrections to the FISAP were made prior to the correction submission deadline date. A review in the Detail Reporting process in Powerfaids was conducted and determined that the process in Powerfaids initially reported that students who should have been included as full time were reverted to part time status if the last period of enrollment was less than fulltime. We have worked with Powerfaids to resolve this issue. Corrections were made to all Part V errors prior to the correction submission date. Payroll has been apprised that only ten percent of the JDL administrator salary can be attributed to and or drawn down from Federal Work Study funds. Anticipated Completion Date: December 1, 2023
Contact Person: Cynthia McCarthy, Director of Financial Aid Corrective Action: Corrective action has been taken to ensure that when students have a spring start date in the prior academic year, the enrollment start date is updated to the correct enrollment start date. A cross check with a selection ...
Contact Person: Cynthia McCarthy, Director of Financial Aid Corrective Action: Corrective action has been taken to ensure that when students have a spring start date in the prior academic year, the enrollment start date is updated to the correct enrollment start date. A cross check with a selection set has been added to capture any incorrect records and adjust accordingly. Anticipated Completion Date: January 3, 2024
Contact Person: Cynthia McCarthy, Director of Financial Aid Corrective Action: For the 2023-2024 academic year Cost of Attendance Budgets were reviewed and tested to correct any miscalculations and omissions. Pell Budgets were updated to correctly differentiate program tuition and fees. Testing for ...
Contact Person: Cynthia McCarthy, Director of Financial Aid Corrective Action: For the 2023-2024 academic year Cost of Attendance Budgets were reviewed and tested to correct any miscalculations and omissions. Pell Budgets were updated to correctly differentiate program tuition and fees. Testing for 2024-2025 academic year has been updated and reviewed to accurately calculate Cost of Attendance Budgets. In some of the findings it was later found that due to changes made in the student’s record, the record should have run through the dynamic redetermination process to update the budget. The staff has been retrained in this process. The process for summer periods of enrollment has been reviewed and revised to flag students who initially applied and or registered for summer classes and subsequently did not register or dropped the classes during the add/drop period and the summer period of enrollment remained thereby calculating a Cost of Attendance for summer. Anticipated Completion Date: January 3, 2024
Contact Person: Tina Paccione, Director of Student Accounts Corrective Action: A turnover in personnel led to inconsistent refund processing for the Summer 2023 semester. There are multiple terms within the summer semester and the new personnel did not run refund files during the first term but ran ...
Contact Person: Tina Paccione, Director of Student Accounts Corrective Action: A turnover in personnel led to inconsistent refund processing for the Summer 2023 semester. There are multiple terms within the summer semester and the new personnel did not run refund files during the first term but ran them during the 2nd term. This is when the loan disbursement was realized and returned. Policies have been set in place outlining disbursement dates that coincide with refund processing dates. Anticipated Completion Date: February 29, 2024
Condition: The University did not return all Title IV funds in a timely manner due to a lack of communication and review. Planned Corrective Action: Management has implemented the following corrective actions: -Beginning with the spring 2024 semester, an internal peer review process was implemented ...
Condition: The University did not return all Title IV funds in a timely manner due to a lack of communication and review. Planned Corrective Action: Management has implemented the following corrective actions: -Beginning with the spring 2024 semester, an internal peer review process was implemented to verify that Title IV funds are returned within the required timeframe. This involves segregation of duties between the completion of each of the following: 1) official and unofficial withdrawal review, 2) verification of this review, and 3) return of the Title IV funding. -Beginning in February 2024, the process team leader within the Office of Student Aid is monitoring system reports on a periodic basis (weekly for official withdrawals, within 45 days of date of determination for unofficial withdrawals) to ensure procedures are being followed. -Beginning in February 2024 for the fall 2023 semester, quality control reviews are being conducted by the Office of Student Aid’s Compliance and Training Team in which withdrawn students are sampled to monitor compliance. These reviews will be conducted at the end of each semester going forward. -Management will update its Return to Title IV (“R2T4”) procedures to reflect these additional controls. Additionally, job aids related to R2T4 have been reviewed and updated where appropriate and ongoing training has been occurring with the R2T4 specialists. Contact person responsible for corrective action: Melissa J. Kunes, Assistant Vice President for Enrollment Management and Executive Director for Student Aid Anticipated Completion Date: 03/31/2024
View Audit 299535 Questioned Costs: $1
Condition: The University did not report certain students' status changes timely to the National Student Loan Data System (NSLDS). Planned Corrective Action: Management has implemented a change in the reporting timeline to ensure that there is adequate time between reporting to National Student Clea...
Condition: The University did not report certain students' status changes timely to the National Student Loan Data System (NSLDS). Planned Corrective Action: Management has implemented a change in the reporting timeline to ensure that there is adequate time between reporting to National Student Clearinghouse and their reporting to NSLDS. In addition, University management will monitor reporting of status changes to NSLDS. Contact person responsible for corrective action: Robert Kubat, Assistant Vice President of Enrollment Management and University Registrar Anticipated Completion Date: 06/30/2024
2023-005 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely. Explanation of disagreement with audit finding: The colleg...
2023-005 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely. Explanation of disagreement with audit finding: The college disagrees with this finding, related to the reporting of five graduate files to NSLDS. The finding states the five files were reported 12 days late of the 60-day reporting requirement. Per section 4.4.2 of the NSLDS Reporting Guide, it is not required that an update be received by NSLDS within two months of the Enrollment Status Effective Date, but rather in the next scheduled enrollment submission. Evidence the graduation status was reported in the next scheduled enrollment submission was provided to the auditors. Action taken in response to finding: The College will continue to closely monitor NSC/ NSLDS reporting schedule and check for transmission errors to ensure compliance with reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Katelyn Dawson Planned completion date for corrective action plan: 6/30/24
2023-004 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend the College implement policies and procedures to identify these requirements and timely report to the appropriate regulators. Explanation of disagreement with audit finding: There is no d...
2023-004 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend the College implement policies and procedures to identify these requirements and timely report to the appropriate regulators. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The college will monitor Dear Colleague Letters and the Federal Student Aid Handbook to ensure compliance with disclosures and reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Jacob Wheeler Planned completion date for corrective action plan: 6/30/24
2023-003 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the student financial aid department develop a process to identify all credit balances are paid timely. Explanation of disagreement with audit finding: There is no disagreement with ...
2023-003 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the student financial aid department develop a process to identify all credit balances are paid timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will conduct a manual review of all refund holds to ensure they are removed to allow timely pay of Title IV credit balances. Name(s) of the contact person(s) responsible for corrective action: Katelyn Dawson Planned completion date for corrective action plan: 6/30/24
2023-002 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Explanation of disagreement with audit finding: There i...
2023-002 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will closely monitor submission dates and work quickly to resolve technology or other discrepancies that result in delays in file transfer to COD within 15 days of the disbursement date. Name(s) of the contact person(s) responsible for corrective action: Katelyn Dawson Planned completion date for corrective action plan: 6/30/24
The Financial Aid Office is in the process of updating all processes and procedures to create checks and balances to ensure that all return of funds are processed appropriately.
The Financial Aid Office is in the process of updating all processes and procedures to create checks and balances to ensure that all return of funds are processed appropriately.
The Financial Aid Office is currently working on updating the Return of Funds procedures, that includes steps to ensure calculations are being processed properly.
The Financial Aid Office is currently working on updating the Return of Funds procedures, that includes steps to ensure calculations are being processed properly.
The Registrars Office and Financial Aid Office are reviewing all current processes to ensure that status changes are being reported accurately. This includes students who may have requested a Refund Exception Appeal, which could have an impact on the date of determination the withdrawal occurred.
The Registrars Office and Financial Aid Office are reviewing all current processes to ensure that status changes are being reported accurately. This includes students who may have requested a Refund Exception Appeal, which could have an impact on the date of determination the withdrawal occurred.
Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform. Explanatio...
Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Recognizing the importance of resolving this finding the University of St Thomas intends to leverage its Internal Audit function in review of its relationship with UAS and the regulations and compliance items therein. Name of the contact person responsible for corrective action: Wade Holmberg Planned completion date for corrective action plan: 6/1/2024
Cash Management Planned Corrective Action: The SFS office will provide the Business Office the types and amounts of funds disbursed. The Business Office will drawdown those amounts from the G5 system. The SFS Office will maintain a roster of the disbursements to validate the amount of funds request...
Cash Management Planned Corrective Action: The SFS office will provide the Business Office the types and amounts of funds disbursed. The Business Office will drawdown those amounts from the G5 system. The SFS Office will maintain a roster of the disbursements to validate the amount of funds requested. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Processing Anticipated Date of Completion: April 2024
Aggregate Federal Direct Loan Limits Planned Corrective Action: Staff training and new reports to identify situations where comment codes related to aggregate limits are identified and reviewed to prevent over awarded funds. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Di...
Aggregate Federal Direct Loan Limits Planned Corrective Action: Staff training and new reports to identify situations where comment codes related to aggregate limits are identified and reviewed to prevent over awarded funds. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Processing Anticipated Date of Completion: February 2024
View Audit 299440 Questioned Costs: $1
Federal Direct Loan (FOL) Monthly Reconciliations Planned Corrective Action: Additional oversight and accountability measures have been put in place to ensure reconciliation is conducted monthly and timely. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Proc...
Federal Direct Loan (FOL) Monthly Reconciliations Planned Corrective Action: Additional oversight and accountability measures have been put in place to ensure reconciliation is conducted monthly and timely. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Processing Anticipated Date of Completion: January 2024
Ineligible Programs Planned Corrective Action: Additional training regarding program eligibility has been conducted with the Processing Team. Previously unknown functionality to designate a program as being ineligible for Title IV aid in the Colleague administrative system was identified and implem...
Ineligible Programs Planned Corrective Action: Additional training regarding program eligibility has been conducted with the Processing Team. Previously unknown functionality to designate a program as being ineligible for Title IV aid in the Colleague administrative system was identified and implemented. Title IV funds can no longer be disbursed for programs marked as ineligible. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Processing Anticipated Date of Completion: February 2024
View Audit 299440 Questioned Costs: $1
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: The university outsourced the R2T4 calculation process in October 2022 to provide timely processing of returns. Additionally, to reduce the overall amount of withdrawal calculations, the university moved from an Ins...
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: The university outsourced the R2T4 calculation process in October 2022 to provide timely processing of returns. Additionally, to reduce the overall amount of withdrawal calculations, the university moved from an Institution Required to Take Attendance to an Institution Not Required to Attendance in May 2023. Additional reports were created to accommodate this change and identify withdrawals. Staff attended the NASFAA R2T4 training course. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Processing Anticipated Date of Completion: November 2023
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