Corrective Action Plans

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Finding 2025-003 – Special Test and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance (See table in Management's Corrective Action Plan"). Condition/Context – Out of a population of approximately 1,000 student status changes a...
Finding 2025-003 – Special Test and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance (See table in Management's Corrective Action Plan"). Condition/Context – Out of a population of approximately 1,000 student status changes and 230 permanent address changes, a sample of 74 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2024-2025 academic year. Auditors believe this to be a representative sample although not a statistical sample. The enrollment information and withdrawal, address change, or graduation date per the University’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Corrective Action Plan: The finding has been addressed through staffing changes and scheduled reporting which took effect January 2026. The office of the University Registrar did not previously have a dedicated staff member to submit reports in a timely manner. With the departure of the Associate Registrar in April 2025, the task fell to several staff members to share the responsibility along with their other tasks. The office currently has an assistant registrar as well as a transcript evaluator who share the responsibility and submit reports once every 30 days, with the exception of winter reporting, which is on a different schedule due to breaks. Internal controls have been revised to check conferral dates prior to submitting the enrollment report for the Main Campus. Name of Contact Person: Julie Khella, University Registrar at jkhella@laverne.edu Projected Completion Date: This was corrected as of March 22, 2026
FINDING 2025-002 – Special Tests and Provisions – Cash Management: Significant Deficiency in Internal Control over Compliance (See table in "Management's Corrective Action Plan"). Condition/Context – The University made 48 draws for various student financial assistance cluster programs. Auditors sel...
FINDING 2025-002 – Special Tests and Provisions – Cash Management: Significant Deficiency in Internal Control over Compliance (See table in "Management's Corrective Action Plan"). Condition/Context – The University made 48 draws for various student financial assistance cluster programs. Auditors selected a sample of 7 and believe this to be a representative sample; however, it was not a statistical sample; Corrective Action Plan: This was done due to the perceived understanding that the new Federal Administration indicated that all grants were at risk of being cancelled and that the G5 website would go dark. Due to the unique nature of the Federal Administration’s perceived announcement, the University would not handle this in the same manner, in the future. If for some reason they were to cancel any future grants, the University would endure the cancellation and close out the grant in the usual process, which is by reimbursement only. Name of Contact Person: Lori Gordien Case, Associate Vice President of Finance and Controller at lgordien@laverne.edu Projected Completion Date: This was corrected as of March 31, 2025.
FINDING 2025-001 – Special Tests and Provisions – Return of Title IV Funds: Significant Deficiency in Internal Control over Compliance; (See table in "Management's Corrective Action Plan"); Condition/Context – Auditors selected a sample of 20 students out of a population of 109 that were identified ...
FINDING 2025-001 – Special Tests and Provisions – Return of Title IV Funds: Significant Deficiency in Internal Control over Compliance; (See table in "Management's Corrective Action Plan"); Condition/Context – Auditors selected a sample of 20 students out of a population of 109 that were identified by the University as having received some federal assistance and withdrew from the University during the year under audit. Auditors believed this to be a representative sample of the population; however, it was not a statistical sample. Corrective Action Plan: The finding has been addressed through the implementation of our FY2024 Corrective Action Plan. The Office of Financial Aid has collaborated with the University Registrar to develop a comprehensive report identifying non-completed courses inclusive of all grade codes. This report is reviewed on the day following faculty submission of final grades for both semester and modular terms. Students subject to R2T4 processing are identified by the Associate Director of Compliance & Special Programs and subsequently assigned to a team of three Program Managers for COD processing. Timely review of this report ensures that all required funds are returned within the 45-day regulatory timeframe. Internal controls have been revised to include a secondary review of all processed R2T4’s. Additionally, an internal control document will be established to demonstrate that R2T4 calculations were reviewed for accuracy and completeness. Name of Contact Person: Laura Evans, Director of Financial Aid at levans2@laverne.edu Projected Completion Date: This was corrected as of March 22, 2026
Department: Health and Human Services Administrative and Financial Services Title: Internal control over Foster Care and Adoption Assistance cash management needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The DHHS Financial Service Center will update...
Department: Health and Human Services Administrative and Financial Services Title: Internal control over Foster Care and Adoption Assistance cash management needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The DHHS Financial Service Center will update the IV-E cash on hand analysis to ensure the cash balances are tracked separately by each of the following Title IV-E programs: Foster Care, Adoption Assistance, Prevention Program and Guardianship Assistance. Completion Date: March 31, 2026 Agency Contact: Sarah Gove, Director, DHHS Service Center, DAFS, 207-458-6626
Department: Health and Human Services Title: Internal control over Foster Care level of care assessments needs improvement Questioned Costs: Known: $3,003 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department will submit Katahdin system enhancements and Level...
Department: Health and Human Services Title: Internal control over Foster Care level of care assessments needs improvement Questioned Costs: Known: $3,003 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department will submit Katahdin system enhancements and Levels of Care (LOC) report updates, to shorten timeframes, and schedule LOC assessments earlier, in order to meet 90-day and 12-month deadlines. The Department will work with vendors to shorten timeframes, to ensure assessments are completed timely. The Department will date and finalize Policy draft for Levels of Care for Resource Homes Chapter 14 with the Policy and Training unit. Completion Date: Jun 30, 2026 (first and second items) and December 31, 2026 (third item) Agency Contact: Robert Blanchard, Associate Director, OCFS, DHHS, 207-624-7955
Student Financial Assistance Cluster – 84.063 – Federal Pell Program Recommendation: We recommend the University should return the overawarded amount of $924 to the US Department of Education and should review and strengthen internal controls over Pell Grant calculations and disbursements to prevent...
Student Financial Assistance Cluster – 84.063 – Federal Pell Program Recommendation: We recommend the University should return the overawarded amount of $924 to the US Department of Education and should review and strengthen internal controls over Pell Grant calculations and disbursements to prevent future over-awards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The institution will implement a recurring enrollment report for Pell-eligible students reflecting enrollment term and registered credits as of the date the report is run. The report will be reviewed weekly during summer terms and after census for fall and spring to identify enrollment changes impacting Pell eligibility. Names of the contact persons responsible for corrective action: Lauren Svanda, Director of Financial Aid Planned completion date for corrective action plan: 05/04/2026
Student Enrollment Status Reporting Errors See 2025-009 for the Corrective action Plan.
Student Enrollment Status Reporting Errors See 2025-009 for the Corrective action Plan.
Financial Assistance Disbursed in Excess of Student Eligibility Modified existing report to include the identification of students with dependent status and independent level loans in the absence of a Parent PLUS denial. Added weekly task to Loan Processing calendar to include the review of report. ...
Financial Assistance Disbursed in Excess of Student Eligibility Modified existing report to include the identification of students with dependent status and independent level loans in the absence of a Parent PLUS denial. Added weekly task to Loan Processing calendar to include the review of report. Corrective Action was Completed on: August 25, 2025.
No Internal Controls Over Student Enrollment Status Reporting See 2025-008 for the Corrective Action Plan.
No Internal Controls Over Student Enrollment Status Reporting See 2025-008 for the Corrective Action Plan.
No Internal Controls Over Student Enrollment Status Reporting See 2025-007 for the Corrective Action Plan.
No Internal Controls Over Student Enrollment Status Reporting See 2025-007 for the Corrective Action Plan.
Financial Assistance Disbursed in Excess of Student Eligibility In September and October 2025, the Director of Student Financial Aid reminded the team members of the mandatory process step which requires them to review each student’s loan history in the NSLDS (National Student Loan Data System) and ...
Financial Assistance Disbursed in Excess of Student Eligibility In September and October 2025, the Director of Student Financial Aid reminded the team members of the mandatory process step which requires them to review each student’s loan history in the NSLDS (National Student Loan Data System) and place a copy of the NSLDS history in the student’s financial aid file as evidence of their review. A review process to confirm compliance was implemented in the fall 2025 semester. An Assistant Director in the Office of Student Financial Aid is responsible for performing audits of our internal files to confirm that the NSLDS reviews are documented. The Assistant Director also provides remediation to any team member whose records are not in compliance. The University has already repaid the over-award amount. Corrective action was completed on: October 29, 2025.
Student Enrollment Status Reporting Errors See 2025-006 for the Corrective Action Plan.
Student Enrollment Status Reporting Errors See 2025-006 for the Corrective Action Plan.
No Internal Controls Over Student Enrollment Status Reporting See 2025-003 for the Corrective Action Plan.
No Internal Controls Over Student Enrollment Status Reporting See 2025-003 for the Corrective Action Plan.
Student Enrollment Status Reporting Errors Collaborate with UNCG Information Technology Services (ITS) to create an automated process to correctly report enrollment status changes with appropriate status dates to the National Student Loan Database System (NSLDS) via the National Clearinghouse (NSC) ...
Student Enrollment Status Reporting Errors Collaborate with UNCG Information Technology Services (ITS) to create an automated process to correctly report enrollment status changes with appropriate status dates to the National Student Loan Database System (NSLDS) via the National Clearinghouse (NSC) when a student adds, drops, or withdraws from one or more (but not all) courses. Develop written policies and procedures that detail how the automated processing reports data, how manual updates are made, how to respond to error reports, and when/how to test samples at NSC and NSLDS on a recurring basis to ensure the process is working as intended. The written policies and procedures will identify key positions within the University Registrar Office and Office of Financial Aid and Scholarships and what each position is responsible for including regularly testing enrollment reporting to ensure NSC and NSLDS are up to date based on the latest enrollment reporting file. Anticipated Completion Date: April 3, 2026.
No Internal Controls Over Student Enrollment Status Reporting Financial Aid Control for NSLDS Enrollment Reporting: •Enrollment is reported via the National Student Clearinghouse by the Registrar. •Financial Aid Staff (Associate Director of Financial Aid) will pull a list of enrolled students for th...
No Internal Controls Over Student Enrollment Status Reporting Financial Aid Control for NSLDS Enrollment Reporting: •Enrollment is reported via the National Student Clearinghouse by the Registrar. •Financial Aid Staff (Associate Director of Financial Aid) will pull a list of enrolled students for the semester and create a sample population for the control check. •Financial Aid Staff (Associate Director of Financial Aid) will Ched each individual student in the Enrollment section of NSLDS to ensure the student's enrollment status has been reported correctly. •Financial Aid Staff (Associate Director of Financial Aid) will perform this check 2-3 weeks after census each semester and document the check in the quality control folder in the shared drive. Corrective Action was Completed on: December 5, 2025.
No Internal Controls Over Student Enrollment Status Reporting Like many schools, ECU relies on the National Student Clearinghouse (NSC) to submit student enrollment status data to the NSLDS (National Student Loan Data System). In response to the audit recommendation, an Assistant Director in the Off...
No Internal Controls Over Student Enrollment Status Reporting Like many schools, ECU relies on the National Student Clearinghouse (NSC) to submit student enrollment status data to the NSLDS (National Student Loan Data System). In response to the audit recommendation, an Assistant Director in the Office of Student Financial Aid has been assigned to regularly review automated reports that identify students whose data in the ECU, NSC, and NSLDS databases doesn’t match. (This task was not completed during the audit period due to position vacancies.) When a student is identified on the error report, the Assistant Director reviews the data in ECU’s student system and the NSLDS to determine the differences and the root cause of the problem. The Financial Aid Office and/or Registrar Office then takes corrective action to ensure the NSLDS record and ECU’s record matches. Corrective action was completed on: October 1, 2025.
Student Enrollment Status Reporting Errors The NSC Parameter Definition (SITS) form in Colleague will be updated to report only active courses at census. As a result of this change, the first of term enrollment submissions to NSCH will reflect all courses enrolled during the semester, and the subseq...
Student Enrollment Status Reporting Errors The NSC Parameter Definition (SITS) form in Colleague will be updated to report only active courses at census. As a result of this change, the first of term enrollment submissions to NSCH will reflect all courses enrolled during the semester, and the subsequent enrollment submissions will only report active courses at the time of the submission. This should accurately report enrollment status changes due to latter 8-week term course enrollment. The update will take place for the Spring 2026 first-of-term submission scheduled for January 30, 2026. Anticipated Completion Date: February 1, 2026.
Financial Assistance Disbursed Without Evaluating Satisfactory Academic Progress SAP Policies and Procedures will be updated to include running the new SAP report during the ISIR Load Process, prior to submitting disbursements, and during the End of Term SAP Evaluation Process to ensure SAP is evalu...
Financial Assistance Disbursed Without Evaluating Satisfactory Academic Progress SAP Policies and Procedures will be updated to include running the new SAP report during the ISIR Load Process, prior to submitting disbursements, and during the End of Term SAP Evaluation Process to ensure SAP is evaluated on all financial aid students. Anticipated Completion Date: February 1, 2026.
Student Enrollment Status Reporting Errors Craven Community College (College) received guidance from the North Carolina System Office to improve the accuracy and timeliness of enrollment reporting. The new process involves updating Colleague system parameters to enhance data gathering and streamline...
Student Enrollment Status Reporting Errors Craven Community College (College) received guidance from the North Carolina System Office to improve the accuracy and timeliness of enrollment reporting. The new process involves updating Colleague system parameters to enhance data gathering and streamline report submissions. The College added an additional report submission following each term to capture graduation status changes. These changes were implemented in September 2025. The College changed the enrollment report submission date to capture student status changes in a timely manner. This change was implemented in September 2025. An Internal Control Process (ICP) will be developed that outlines steps to be taken to conduct two self-audits each semester. The ICP will be located on the college’s shared drive accessible by all employees. The ICP will be available by March 1, 2026. The College will self-audit student records submitted to the National Clearinghouse and National Student Loan Data System (NSLDS) twice per semester at the mid-point and at end-of-term. The self-audit will be conducted by the Executive Director of Financial Aid and the Director of Admissions and Student Records. The Directors will review a total of 50 files per audit. A record of each audit will be stored on the secured shared directory. The shared directory can only be accessed by the staff in Student Services. The first self-audit will occur during March 2026. Anticipated Completion Date: June 30, 2026.
No Internal Controls Over Student Enrollment Status Reporting Assignment of Responsibility: The Registrar will provide a copy of each NSC enrollment report to the Director of Financial Aid for review. The Director of Financial Aid will review a sample of students included in the report by comparing ...
No Internal Controls Over Student Enrollment Status Reporting Assignment of Responsibility: The Registrar will provide a copy of each NSC enrollment report to the Director of Financial Aid for review. The Director of Financial Aid will review a sample of students included in the report by comparing enrollment information with records in the National Student Loan Data System (NSLDS). Any discrepancies or enrollment status changes not accurately reflected in NSLDS will be identified and corrected in a timely manner. This review and reconciliation process will be conducted monthly for enrollment status changes and once per semester for graduation status updates. Written Policies and Procedures: CFCC maintains an internal document that outlines the procedures required to complete all NSC reporting. This document will be updated to incorporate the reconciliation and review process involving the Director of Financial Aid to ensure accuracy, consistency, and continuity. Corrective action was completed on: January 21, 2026.
Student Enrollment Status Reporting Errors Since October 2025, the College has operated under a rigorous review process. This initiative is managed through a cross-functional collaboration between Financial Aid and Records and Registration, with executive oversight provided by the Vice President of ...
Student Enrollment Status Reporting Errors Since October 2025, the College has operated under a rigorous review process. This initiative is managed through a cross-functional collaboration between Financial Aid and Records and Registration, with executive oversight provided by the Vice President of Student Services, the Executive Director of Enrollment Management, and the Director of Financial Aid. •Error Resolution and Reconciliation: Error files and NSLDS reject logs are shared immediately with the Financial Aid Director. Staff are required to review every student flagged in these files and verify that corrections are accurately reflected in the NSLDS database. Process implemented since October 2025. •Increase in Control: To streamline communication and sharing of information, CCC& Tl is launching a centralized Microsoft Teams site for all stakeholders. This site will serve as a repository for National Student Clearinghouse (NSC) term enrollment status error files, graduate error files, and comprehensive PDF lists of all students submitted to the NSC. The site will also include written procedures for identifying and reporting enrollment status changes, and defined roles and responsibilities. Process to be completed by March 13, 2026. •Staff Training and Accountability: All relevant staff will receive comprehensive training on these new protocols. A standardized checklist has been developed to track completed steps. Process will be completed by March 13, 2026. These steps are designed to increase control and significantly improve the accuracy and timeliness of student status updates, thereby ensuring full compliance with state and federal reporting requirements. Anticipated Completion Date: March 13, 2026.
The Financial Aid Office identified suspicious activity in FY2025 and collaborated with IT and Admissions to verify the integrity of financial aid applications. The Financial Aid Office has implemented additional procedures and reporting controls to strengthen the financial aid awarding process. Dur...
The Financial Aid Office identified suspicious activity in FY2025 and collaborated with IT and Admissions to verify the integrity of financial aid applications. The Financial Aid Office has implemented additional procedures and reporting controls to strengthen the financial aid awarding process. During the packaging process, a report is generated and reviewed to verify the Cost of Attendance (COA), Student Aid Index (SAI), and any other estimated financial assistance prior to loan disbursement. This review helps ensure that total financial aid does not exceed allowable limits and prevents the overawarding of aid to students.
Student Financial Assistance Cluster – 84.063 Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit findin...
Student Financial Assistance Cluster – 84.063 Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Upon notification of the finding, a query was developed and a review performed to identify potentially impacted records in advance of the 2025-2026 academic year. The University has also added review mechanisms to its semester-based enrollment adjustment and repackaging process designed to identify Enrollment Intensity (EI) coding changes, either by batch or manual processes. These review mechanisms allowed for the increased monitoring and correction of potentially incorrect EI coding that would ultimately increase the likelihood of an incorrect Pell Grant amount. A formal bi-weekly query and review process has recently been implemented that compares the student’s total enrollment for a term with the coded EI, confirming accuracy of the EI percentage. The query process also checks that the posted Pell award is the correct amount based on the EI percentage. Name(s) of the contact person(s) responsible for corrective action: Connie Smith, Executive Director of Student Financial Services Planned completion date for corrective action plan: March 2026
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to National Student Loan Data System (NSLDS) within the appropriate timeframe as requ...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to National Student Loan Data System (NSLDS) within the appropriate timeframe as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A weekly query process was implemented to identify continuing, degree-seeking students with cancellations or term withdrawals. This process allows us to identify this population of students and accurately report status changes to National Student Clearinghouse (NSC) within a week, ensuring plenty of time for information to be sent from NSC to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Jack Campbell, Registrar, University of Maine and Saman Lesinski, Senior Associate Registrar, University of Southern Maine Planned completion date for corrective action plan: University of Maine – August 2025, University of Southern Maine – March 2026
Finding 2025-001 Condition During our audit, for 1 out of 25 students selected for testing, the College did not report to the National Student Clearninghouse (NSC) and the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, the...
Finding 2025-001 Condition During our audit, for 1 out of 25 students selected for testing, the College did not report to the National Student Clearninghouse (NSC) and the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, the student was ultimately reported to the NSC and NSLDS. Corrective Action Plan The graduation status of the student was not reported to NSC and NSLDS in a timely manner. The student qualified as a May 2025 graduate. However, at the point in time at which May graduates were reported to NSC, the final transcripts for the off-campus credits the student used to complete his degree had not yet been received. As a result, his degree was not conferred in the student information system until after the degree upload was sent to NSC. Then, by human error, once the student’s transcripts were received, his graduation status was not manually reported to NSC until after the 60-day reporting period had passed. To prevent this situation from arising in the future, we have changed the way we track students whose degree conferrals are entered into the SIS after the date on which the graduates upload has been sent to NSC. This process change will highlight those students whose conferrals must be manually reported to NSC because they were not included in the initial upload of graduates sent to NSC. We will also require students sending transcripts for credits taken off campus to have those transcripts received by our office within 30 days of the conferral date. If transcripts containing credits necessary for graduation are received more than 30 days after the conferral date, the student’s degree conferral will be pushed back to the next available degree conferral data. Name of Contact Person Responsible for Corrective Action: Michael Reig, Registrar Completion Date: December 1, 2025
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