Corrective Action Plans

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

Questioned Costs Student Financial Aid Reporting

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 Questioned Costs Student Financial Aid

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 Questioned Costs Student Financial Aid

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 Questioned Costs § 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

Questioned Costs Student Financial Aid Eligibility

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

View Audit 300369

Finding 389377 (2023-005)

Significant Deficiency 2023

South Carolina State University

SC

Internal Control / Segregation of Duties Special Tests & Provisions Questioned Costs

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

View Audit 300369

Finding 389363 (2023-001)

Significant Deficiency 2023

South Carolina State University

SC

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

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 agencies. 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. Management and implementation of current corrective plans are critical to the compliance efforts of the University: The University has made the necessary changes to the staff and will continue to assess the efficiency of the review process to include, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University’s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. 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 offices (Director of Financial Aid and Director of Transfer Students). The University is requesting a report be filed on the status of our transfer students 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 its oversight and management of the corrective action plans through the new internal audit unit until this matter has been resolved. Anticipated Completion Date: June 30, 2024

View Audit 300369

Finding 389359 (2023-001)

Significant Deficiency 2023

Molloy College

NY

Student Financial Aid Special Tests & Provisions Reporting

Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Finding 2023-001 – Special Tests and Provisions – Enrollment Reporting Name of contact person responsible for corrective action: Linda Albanese, Vice President Enrollment Management; lalbanese@molloy.edu; 516-323-4025 Molloy University u...

Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Finding 2023-001 – Special Tests and Provisions – Enrollment Reporting Name of contact person responsible for corrective action: Linda Albanese, Vice President Enrollment Management; lalbanese@molloy.edu; 516-323-4025 Molloy University understands the finding and has devised a process to ensure students who submit a request to withdraw which is effective after the completion of the current semester get processed manually in NSLDS once the semester has ended. To aid in this updated practice, a documented procedure has been established that provides a checklist of steps and collection of internal signatures to be completed for each student who indicates they wish to withdraw from the University. Additionally, we will be engaging a consultant to perform a compliance review with the US Department of Education for Enrollment Reporting. This will ensure that the withdrawal status is promptly provided within the required timeframe. Proposed completion date: February 20, 2024

View Audit 300357

Finding 389356 (2023-002)

Significant Deficiency 2023

Antioch University

OH

Special Tests & Provisions Questioned Costs Student Financial Aid

Corrective Action Taken or Planned: The University has experienced changes in staffing for personnel involved in enrollment reporting and system irregularities with multiple programs with the National Clearing House. These inconsistencies have caused delays in processing and response to enrollment r...

Corrective Action Taken or Planned: The University has experienced changes in staffing for personnel involved in enrollment reporting and system irregularities with multiple programs with the National Clearing House. These inconsistencies have caused delays in processing and response to enrollment reporting changes. Antioch University has hired a new Director of Records Administration with a primary responsibility for NSLDS reporting. The University will implement a comprehensive training plan for new individuals and teams, including improved documentation of procedures, increased clarity regarding the process for the necessity of error resolution, and a review of system processing to help reduce errors in reporting and increase efficiency. In addition, internal reviews and control audits will be performed throughout the year to ensure accuracy in NSLDS reporting and alignment with the National Clearing House guidance. Person Responsible for Corrective Action: Maureen Heacock, the Registrar and Katy Stahl, Executive Director of Financial Aid & Scholarships are responsible for executing the corrective action plan. Anticipated Completion Date: Fiscal year 2024

View Audit 300356

Finding 389355 (2023-001)

Significant Deficiency 2023

Antioch University

OH

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action Taken or Planned: Starting with the 2024-2025 Award year, the Office of Financial Aid and Scholarships is undergoing an internal reorganization. The purpose of this is to provide a broader depth of knowledge and better dual control and compliance functions within the Office of Fina...

Corrective Action Taken or Planned: Starting with the 2024-2025 Award year, the Office of Financial Aid and Scholarships is undergoing an internal reorganization. The purpose of this is to provide a broader depth of knowledge and better dual control and compliance functions within the Office of Financial Aid and Scholarships. In the new reorganization structure, the FA Specialist will be responsible for performing the R2T4 Calculations, with their Supervisor, the Assistant Director of Financial Aid Operations, reviewing and approving the calculation. Once the calculation is completed, and signed off on by the Assistant Director, the FA Specialist will will complete and send the Financial Aid Transmittal Register (FATR) report and notify the Student Accounts Office so they can process the return of funds on through the Financial Aid Posting Register (FATP). Review of the Financial Aid Posting Register will be done by the FA Specialist to ensure the internal process to return funds is timely and posted to the Common Origination and Disbursement system accurately. A quarterly review and internal control audit of Title IV refund calculations will also be completed to ensure accuracy in system processing, days and break calculations, and adherence to Title IV regulations. In addition, the staff will have additional training throughout the year on Title IV compliance and refunds to ensure the University is compliant with all regulations. Person Responsible for Corrective Action: Katy Stahl, the Executive Director of Financial Aid & Scholarships, is responsible for the execution of the corrective action plan. Anticipated Completion Date: Fiscal year 2024

View Audit 300356

Finding 389281 (2023-001)

Significant Deficiency 2023

Hagerstown Community College

MD

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

Hagerstown Community College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the num...

Hagerstown Community College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS- FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2023-001 NSLDS Enrollment Reporting Student Financial Aid Cluster-Assistance Listing No. 84.063, 84.268 Condition: During testing of enrollment status reporting, we noted that the incorrect enrollment status and effective date was reported to NSLDS. Recommendation: The College should evaluate their procedures and policies related to reporting status changes to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Cause-Enrollment Status Reporting: Hagerstown Community College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student enrollment status corrections were uploaded to NSC timely and correctly; however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate and timely update to the enrollment statuses in NSLDS. No review was completed to ensure the upload was completed in NSLDS. Cause for Effective Date Reporting - Hagerstown Community College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student effective date corrections were uploaded to NSC correctly; however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate update of the status effective date NSLDS. No review was completed to ensure the upload was completed in NSLDS. The following actions have been implemented to resolve the deficiencies: The Director of Financial Aid has reached out to NSC to determine the errors in the file transmissions. NSC responded back with the issues that need to be research by HCC's Student Financial Aid Office and Registrar's office. Both offices will collaborate to identify the error and develop procedures to minimize the error from happening again. HCC plans to review the reporting procedures for withdrawn and graduating students. NSC sent HCC a detailed explanation of what needs to be reviewed to make sure the correct information is transmitted. Name(s) of the contact person(s) responsible for corrective action: Dr. Charles M. Scheetz, Director of Financial Aid and W. Christopher Baer, Registrar Planned completion date for corrective action plan: Summer 2024

View Audit 300295

Finding 389279 (2023-003)

Material Weakness 2023

Saint Louis University

MO

Matching / Level of Effort / Earmarking Student Financial Aid Internal Control / Segregation of Duties § 200.303

Based on the recommendations outlined in this report, we are committed to enhancing our internal control process to ensure timely submission of Direct Loan and Pell Grant disbursement records to COD. This includes allocating necessary resources, providing additional training, and implementing robust...

Based on the recommendations outlined in this report, we are committed to enhancing our internal control process to ensure timely submission of Direct Loan and Pell Grant disbursement records to COD. This includes allocating necessary resources, providing additional training, and implementing robust monitoring and oversight mechanisms to address capacity constraints effectively and prevent future instances of noncompliance. Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above items by June 2024.

View Audit 300294

Corrective Action Plans

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