Corrective Action Plans

Finding 88179 (2022-003)

Significant Deficiency 2022

SD

Student Financial Aid Reporting Special Tests & Provisions

Finding 2022-003 Special Tests and Provisions ? Return of Title IV Funds ? Calculation of the Amount of Title IV Assistance to be Returned, Timely Return of Funds Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFD...

Finding 2022-003 Special Tests and Provisions ? Return of Title IV Funds ? Calculation of the Amount of Title IV Assistance to be Returned, Timely Return of Funds Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 ? Federal Pell Grant Program Finding Summary: During testing over return of Title IV funds, the following deficiencies were noted: ? 5 of 8 students? percentage completion rate were calculated incorrectly which resulted in 3 of the 8 students not having the correct amount of Title IV funds to be returned. ? 1 of 8 students did not return Title IV funds in the required time frame. Responsible Individuals: James (Rocky) Query, Interim CFO and Jessica Papa, Director of Financial Aid Corrective Action Plan: The Business Office and Financial Aid Office have examined the internal control processes to address shortcomings that have contributed to deficiencies in the calculation and return of Title IV funds. External review of internal controls during the Spring term may contribute to further corrective actions. All required corrections in student accounts noted in the findings have been made. Anticipated Completion Date: Review and corrective action ongoing.

View Audit 79889

Finding 72371 (2022-002)

Material Weakness 2022

Sierra Nevada College

NV

Student Financial Aid Material Weakness Significant Deficiency

Finding 2022-002 U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Assistance Listing 84.268 Federal Pell Grant, Assistance Listing 84.063 Federal Work Study Program, Assistance Listing 84.033 Federal Supplemental Education Opportunity Grants, Assi...

Finding 2022-002 U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Assistance Listing 84.268 Federal Pell Grant, Assistance Listing 84.063 Federal Work Study Program, Assistance Listing 84.033 Federal Supplemental Education Opportunity Grants, Assistance Listing 84.007 Teacher Education Assistance For College and Higher Education Grants, Assistance Listing 84.379 P268K220568, P063P210568, P033A212492, P007A212492, P379T220568 Special Test and Provisions ? Return of Title IV Funds Material Weakness in Internal Control over Compliance Finding Summary: In the current year, there was no evidence of an independent review over the return of Title IV calculations. Responsible Individuals: Maia Rowland, Student Financial Aid Director Corrective Action Plan: This issue will cease to exist in the future due to the acquisition of SNU by UNR. The acquisition of SNU by UNR was effective July 1, 2022. Anticipated Completion Date: This issue will cease to exist in the future due to the acquisition of SNU by UNR. The acquisition of SNU by UNR was effective July 1, 2022.

View Audit 64382

Finding 72324 (2022-001)

None 2022

William Marsh Rice University

TX

Student Financial Aid Matching / Level of Effort / Earmarking

Management accepts the recommendation to request from students receiving federal financial assistance voluntary consent to participate in electronic transactions. The Corrective Action Plan is as follows: Effective December 1, 2022, the University added language to its NetID and other communicatio...

Management accepts the recommendation to request from students receiving federal financial assistance voluntary consent to participate in electronic transactions. The Corrective Action Plan is as follows: Effective December 1, 2022, the University added language to its NetID and other communication portals outlining the policy and obtaining a student?s consent for electronic transactions. 1. The Voluntary Consent for Electronic Transactions was added to our consumer information page. https://financialaid.rice.edu/forms-resources/consumer-information 2. The Voluntary Consent for Electronic Transactions was added to the https://mynetid.rice.edu/ page. Effective Date: December 1, 2022 Person responsible for implementation: Paul Negrete, Executive Director for University Financial Aid Services, 713-348-5905

View Audit 63485

Finding 71812 (2022-002)

Material Weakness 2022

Shawnee State University

OH

Student Financial Aid Material Weakness Reporting

Finding Number: 2022-002 Condition: Shawnee State University did not report student status changes timely and accurately for certain students who graduated or withdrew during the year. Planned Corrective Action: Prior to an enrollment report being uploaded to the National Student Clearinghouse, the ...

Finding Number: 2022-002 Condition: Shawnee State University did not report student status changes timely and accurately for certain students who graduated or withdrew during the year. Planned Corrective Action: Prior to an enrollment report being uploaded to the National Student Clearinghouse, the Recalculate Academic Record process in our student information system, currently J1, will be ran to identify any student registration records that may be stuck in a current status due to a mixed Repeat status. Those records will be corrected as needed. The office underwent major staffing changes, which caused a delay in submitting reports in a timelier manner. The staffing issues have been resolved and reports are uploaded on the scheduled submission date. Contact person responsible for corrective action: Tamara Sheets Anticipated Completion Date: 10/6/2022

View Audit 64280

Finding 71811 (2022-001)

Material Weakness 2022

Shawnee State University

OH

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

Finding Number: 2022-001 Condition: The University did not return title IV funds to the Department of Education within the required time frame for certain students who required a return of funds and did not identify all students initially that required a return of title IV. Planned Corrective Action...

Finding Number: 2022-001 Condition: The University did not return title IV funds to the Department of Education within the required time frame for certain students who required a return of funds and did not identify all students initially that required a return of title IV. Planned Corrective Action: Upon notification of Finding No. 2021-003, a new R2T4 process was created for the Spring 2022 academic term. This process consists of a new report created to identify students who withdrew from all courses during each academic term. Once the R2T4 calculation is completed, the aid adjustment is made in the financial aid system and posted to the student's account the same day. The aid amounts are manually adjusted in COD. All errors related to finding No. 2022-001 are from Summer 2021 academic term and the Fall 2021 academic term. There were no errors in the audit sample for Spring 2022. The new process continues to be in place. Contact person responsible for corrective action: Nicole Neal Anticipated Completion Date: 10/6/2022

View Audit 64280

Finding 71657 (2022-002)

None 2022

Southwestern Adventist University

TX

Questioned Costs Student Financial Aid Eligibility

Corrective Action: New student information system has processes in place that will prevent over awarding/over payments, assisting reduce human error. Contact Person: Duane Valencia, Assistant Financial Vice President Completion Date: Began School year 22-23, ongoing

View Audit 65445 Questioned Costs: $1

Finding 71653 (2022-003)

Significant Deficiency 2022

Southwestern Adventist University

TX

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

Corrective Action: We have hired additional full-time staff who is being trained and will be overseeing the document requirements for student files. Contact Person: Duane Valencia, Assistant Financial Vice President Completion Date: In progress, staff hired Spring ?23. Currently in training, on...

Corrective Action: We have hired additional full-time staff who is being trained and will be overseeing the document requirements for student files. Contact Person: Duane Valencia, Assistant Financial Vice President Completion Date: In progress, staff hired Spring ?23. Currently in training, ongoing.

View Audit 65445

Finding 66160 (2022-001)

Significant Deficiency 2022

Dallas Theological Seminary

TX

Student Financial Aid Reporting Significant Deficiency

Enrollment Reporting to NSLDS Planned Corrective Action: The registrar?s office (RO) will begin using the Status Discrepancy report that is available in Anthology to identify conflicting information on a student-by-student basis. This report will help in resolving status discrepancies prior to sub...

Enrollment Reporting to NSLDS Planned Corrective Action: The registrar?s office (RO) will begin using the Status Discrepancy report that is available in Anthology to identify conflicting information on a student-by-student basis. This report will help in resolving status discrepancies prior to submitting the report to NSC. Once the Enrollment Report is submitted, the RO will promptly resolve any Error Resolution Reports received from NSC and submit corrections. The RO will continue to follow up with NSC on the status of data transmissions. Person Responsible for Corrective Action Plan: Sabrina Hopson Anticipated Date of Completion: July 2023

View Audit 62040

Finding 65281 (2022-001)

Significant Deficiency 2022

Maryland Institute College of Art

MD

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

Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster AL Number: 84.063 Finding Number: 2022-001 Department?s Response: Management recognizes the finding in Pell disbursement reporting to the Common Origination and Disbursement (COD) System (OMB No. 1845-...

Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster AL Number: 84.063 Finding Number: 2022-001 Department?s Response: Management recognizes the finding in Pell disbursement reporting to the Common Origination and Disbursement (COD) System (OMB No. 1845-0039). The COVID-19 Pandemic has presented the financial aid office with unprecedented administrative challenges, and we continue our efforts to return to pre-pandemic norms. Management would like to acknowledge the deficiency did not result in ineligible payments to students nor required the college to return any Title IV funds. Planned Corrective Action: As recommended the financial aid office has implemented additional monitoring controls. Management will develop a process to perform secondary reviews of all Pell disbursements reporting prior to the COD reporting deadline, and the Associate Vice President for Financial Aid is now actively involved in ensuring timely reporting disbursements by reviewing monthly internal reports. Anticipated Completion Date: May 31, 2023 Name and title of responsible contact: If you have any questions, please contact De Rodrick Jonkins AVP for Financial Aid, Maryland Institute College of Art djonkins@mica.edu.

View Audit 67388

Finding 65274 (2022-002)

Significant Deficiency 2022

Solano Community College District

CA

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

U.S. Department of Education 2022-002: Student Financial Assistance Cluster ? Student Eligibility and Awarding ? Assistance Listing Number: 84.268 Recommendation: We recommend the College to evaluate its procedures related to the manual input of information from the student loan request. Explanation...

U.S. Department of Education 2022-002: Student Financial Assistance Cluster ? Student Eligibility and Awarding ? Assistance Listing Number: 84.268 Recommendation: We recommend the College to evaluate its procedures related to the manual input of information from the student loan request. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This issue was discovered during the audit process, and we performed the following activities in response: ? We consulted with the auditing team?s national resource about the proper way to correct this award. Implemented by August 2022. ? Following their guidance, we corrected the student?s awards so that the appropriate amount of sub and unsub were in place and then re-ran her R2T4 calculation to make sure everything was correct in our system and on COD. Implemented by September 2022 ? We conducted a review of our other Direct Loan awards, and found that this incident was an isolated manual mistake, not a systemic one. Implemented by August 2022 ? Although the person responsible for this error is no longer employed in the financial aid department, we have done training with the current Direct Loan coordinator to reduce the likelihood of this mistake in the future. Implemented by August 2022 ? We modified the Direct Loan procedure log to include a reminder about this regulation. Implemented by August 2022 Name(s) of the contact person(s) responsible for corrective action: Alysa Borelli, Dean of Enrollment and Student Services. Planned completion date for corrective action plan: The corrective action plan was implemented by September 2022.

View Audit 62600 Questioned Costs: $1

Finding 64497 (2022-002)

Significant Deficiency 2022

Northwest Nazarene University

ID

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

2022-002 Student Financial Assistance Cluster ? ALN 84.007/84.033/84.038/84.063/84.268/84.379 Recommendation: We recommend the University reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Explanation...

2022-002 Student Financial Assistance Cluster ? ALN 84.007/84.033/84.038/84.063/84.268/84.379 Recommendation: We recommend the University reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In the fall of 2021, the University changed banking relationships. Outstanding checks from the former bank were cancelled and a check was issued from the new bank. The reissuance of checks showed a flaw in our 240-day reconciliation tool which focused on the check date rather than the original disbursement date. This was an isolated issue and we have adjusted our 240-day review tool to calculate based on the original disbursement date. Name(s) of the contact person(s) responsible for corrective action: John Greentree, Controller Planned completion date for corrective action plan: Completed as of September 2022

View Audit 75144

Finding 64472 (2022-002)

Material Weakness 2022

Eastern University

PA

Student Financial Aid Material Weakness Internal Control / Segregation of Duties

Return of Title IV (R2T4) Calculations Planned Corrective Action: I met with our Registrar, our Brightspace Administrator, our Assistant Provost and a faculty member of our Data Science department to collaborate on how to properly identify and document online student?s attendance, participation, and...

Return of Title IV (R2T4) Calculations Planned Corrective Action: I met with our Registrar, our Brightspace Administrator, our Assistant Provost and a faculty member of our Data Science department to collaborate on how to properly identify and document online student?s attendance, participation, and activity. We have already crafted a report that captures this information and we will continue to add to this report and utilize it for the current year to determine any adjustments that need to be made to Federal Student Aid. We are meeting again this week to discuss and finalize this report and test it out repeatedly to ensure it captures the right information every time. Person Responsible for Corrective Action Plan: Andrea L Ruth, Director of Financial Aid Anticipated Date of Completion: 4/1/2023

View Audit 73872

Finding 64471 (2022-001)

Material Weakness 2022

Eastern University

PA

Student Financial Aid Material Weakness

Lack of Administrative Capability Planned Corrective Action: We have re-reviewed the COVID waivers and made the necessary notes and documentation in our records. Our office is actively recruiting an additional aid counselor to assist with the increased workload due to our significant jump in enrollm...

Lack of Administrative Capability Planned Corrective Action: We have re-reviewed the COVID waivers and made the necessary notes and documentation in our records. Our office is actively recruiting an additional aid counselor to assist with the increased workload due to our significant jump in enrollment (up 52% in the last two years). We are working with our Registrar, Assistant Provost, Brightspace Administrator, and IT to ensure our system is reporting the right information at the right time to the right departments. We have sought guidance from our Department of Education representative in Philadelphia to make sure we are interpreting regulations and guidelines appropriately. We have changed our policies for this upcoming 2023-2024 school year to not disburse any aid until after all of our terms for a given semester have passed their add/drop periods so we can ensure that each student has actively started their program, is continuing to be an active participant, and if not, that we take the necessary steps to adjust or cancel their aid appropriately. This is not something that we take lightly and are determined to correct these issues and take additional preventative measures so that they do not happen again. Person Responsible for Corrective Action Plan: Andrea L Ruth, Director of Financial Aid Anticipated Date of Completion: 4/1/2023

View Audit 73872

Finding 64467 (2022-001)

Significant Deficiency 2022

Molloy College

NY

Student Financial Aid Procurement, Suspension & Debarment Reporting

Corrective Action Plan Finding 2022-001 ? Special Tests and Provisions ? Enrollment Reporting Compliance and Internal Control (Significant Deficiency) University's response: We concur. Name of contact person responsible for corrective action: Linda Albanese, Vice President Enrollment Management C...

Corrective Action Plan Finding 2022-001 ? Special Tests and Provisions ? Enrollment Reporting Compliance and Internal Control (Significant Deficiency) University's response: We concur. Name of contact person responsible for corrective action: Linda Albanese, Vice President Enrollment Management Corrective action: In response to the Enrollment Reporting audit finding, Molloy University will continue to check the NSLDS homepage Announcement section multiple times per week for any notice that the Enrollment History Update page is functioning. We are also subscribed to email communications from Compliance & Data Ops Managing Director of the National Student Clearinghouse (NSC) and the New York State Financial Aid Administrators (NYSFAAA). The re opening of the Enrollment History page will be announced through any of these venues or by electronic announcement from the Federal Student Aid (FSA) Office of the U.S. Department of Education. While Molloy certification dates are correct in our student information system, Jenzabar, the certification date in the National Student Loan Data System (NSLDS) prints as MM/DD/YYYY or the current date because the new website is not working properly. This is an NSLDS issue, and the University was advised not to make any changes in the site at this time. As per guidance from FSA, Molloy has retained copies of all announcements as documentation for audit purposes. These electronic announcements highlight the issues relating to the retirement of the old NSLDS website and the launch of the new website. Electronic announcements between June and November 2022 identified enrollment functionality issues. And the update to the November announcement reported the enrollment roster dissemination delay. The latest electronic announcement in January 2023 confirmed that colleges were not able to comply with enrollment reporting requirements. While Molloy continues to monitor all updates regarding the site, the University has also proactively reached out to the NSLDS Customer Service Center. In Case #221208 000270 the reply, dated December 8, 2022, confirmed that the errors reflected in NSLDS were not the fault of Molloy, but rather due to the issues with the NSLDS website. As soon as the suspension of the NSLDS Enrollment History Update functionality is lifted, Molloy will make the necessary updates. Proposed Completion Date: As soon as the suspension of the NSLDS Enrollment History Update functionality is lifted, Molloy University will make the necessary updates.

View Audit 73870

Finding 63664 (2022-001)

Significant Deficiency 2022

Foothill - De Anza Community College District

CA

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

2022-001 Student Financial Aid Cluster ? Enrollment Reporting ? Various Recommendation: We recommend that each College review their existing procedures and controls and identify necessary changes needed to ensure timely reporting of student status changes to NSLDS as required by regulations. Foothil...

2022-001 Student Financial Aid Cluster ? Enrollment Reporting ? Various Recommendation: We recommend that each College review their existing procedures and controls and identify necessary changes needed to ensure timely reporting of student status changes to NSLDS as required by regulations. Foothill College Response Explanation of disagreement with finding: There is no disagreement with the finding and the Foothill College will resolve it. Action taken in response to finding: Using the samples from the findings as an example, the Dean of Enrollment Services will contact with National Student Clearinghouse Audit support and request a review of the data received from the College by 3/1/2023. If the issue is with our data, the College with work our technical support team and request a specialist from Ellucian ? Banner that supports the enrollment reporting process. If the issue is merely additional training needed on how to handle the error report file, then additional training will be requested for appropriate Admissions & Records staff for one-on-one training with the National Student Clearinghouse. Name of the contact person responsible for corrective action: Anthony Cervantes, Dean of Enrollment Services Planned completion date for corrective action plan: April 1, 2023. De Anza College Response Explanation of disagreement with finding: De Anza College has reported all five students in question within 30 days of their status change to the National Clearing House. However, the NCH failed to report to the NSLDS the change of status within 30 days after we correctly reported the change in enrollment. The College has provided proof of our reporting to the NCH, but because the students were not reported by the NCH in a timely manner, we are responsible to take actions to correct this process and make sure that the NCH is reporting on time and with right reports. Action taken in response to finding: The College can see some improvement in numbers of unreported or misreported student records from the NCH to the NSLDS. The Dean of Enrollment Services will continue working with the National Clearing House on the reporting process to avoid discrepancies and delays in the future. Name of the contact person responsible for corrective action: Nazy Galoyan, Dean of Enrollment Services Planned completion date for corrective action plan: June 2023.

View Audit 68659

Finding 62571 (2022-001)

Significant Deficiency 2022

Boise State University

ID

Student Financial Aid Matching / Level of Effort / Earmarking

Federal Program Title: Student Financial Assistance Cluster ALN: 84.007, 84.038, 84.063, 84.268, 84.379 Recommendation: We recommend the University update their R2T4 calculation process to eliminate the students that completed 49% of the payment period days in their modular classes. We also recomm...

Federal Program Title: Student Financial Assistance Cluster ALN: 84.007, 84.038, 84.063, 84.268, 84.379 Recommendation: We recommend the University update their R2T4 calculation process to eliminate the students that completed 49% of the payment period days in their modular classes. We also recommend the University review the calculation for automatic last date of attendance overrides. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Financial Aid and Scholarships office has created the following workflow queries to systematically review R2T4 calculations for accuracy: 1) BFA_R2T4_MOD_ONLY_AUDIT_1 -- module-only students who have earned more that 49% and have an R2T4 calculation. 2) BFA_R2T4_MOD_ONLY_AUDIT_2 -- the percent earned on the Return TIV Session does not match the Pct. TIV Aid Earned on the Worksheet. 3) BFA_R2T4_MOD_ONLY_AUDIT_3 -- if there are two withdrawal dates, the latest is used in the worksheet. These queries will become part of the monthly workflows and alert management for additional review. Name(s) of the contact person(s) responsible for corrective action: Kelley Christianson, Director of Financial Aid and Scholarships: kelleychristianson@boisestate.edu Planned completion date for corrective action plan: March 31, 2023

View Audit 54662

Finding 62143 (2022-003)

Significant Deficiency 2022

Marymount Manhattan College

NY

Student Financial Aid Special Tests & Provisions Eligibility

Name of contact person: Chris Pesotski Corrective action: With respect to the finding relating to program length issues, the College agrees with this finding and will make appropriate changes to ensure that the NSLDS records for program length are based on years, correcting the earlier issue of bas...

Name of contact person: Chris Pesotski Corrective action: With respect to the finding relating to program length issues, the College agrees with this finding and will make appropriate changes to ensure that the NSLDS records for program length are based on years, correcting the earlier issue of basing program length by weeks. With respect to the program change date record retention issue, the College agrees with this finding and will take appropriate actions to correct this issue. These actions will include retraining of staff to reinforce the necessity of retaining the records, providing adequate secure storage facilities for paper records and conducting regular quality control exercises to ensure that this issue does not re-occur. Proposed completion date: 6/30/2023

View Audit 57169

Finding 62042 (2022-001)

None 2022

Thiel College

PA

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

Finding 2022-001: Return of Title IV Funds Federal Program: Student Financial Assistance Cluster - Federal Pell Grant Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.063 Federal Award Year: June 30, 2022 Criterion: 34 CFR 668.22...

Finding 2022-001: Return of Title IV Funds Federal Program: Student Financial Assistance Cluster - Federal Pell Grant Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.063 Federal Award Year: June 30, 2022 Criterion: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Corrective Action Plan The College will make timely returns of Title IV funds within the required 45-day requirement. The withdrawal date determination will be made no later than 30 days after the end of the earliest the earliest of the (1) payment period or period of enrollment, (2) academic year, or (3) educational period, as appropriate. Return to Title IV calculations will be completed with applicable dates and required aid adjustments will be made accordingly. Implementation will begin immediately. Kim Peters and/or Denise Owens will initiate all transactions, Michelle Work will approve. Responsible Persons Michelle Work, Director of Financial Aid Anticipated Completion Date This is an ongoing process and will begin immediately.

View Audit 50214

Finding 61897 (2022-001)

Significant Deficiency 2022

Asbury Theological Seminary

KY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Asbury Theological Seminary respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Blue & Company, LLC; 250 West Main Street, Suite 2900; Lexington, Kentucky 40507. The finding from the schedule of findings ...

Asbury Theological Seminary respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Blue & Company, LLC; 250 West Main Street, Suite 2900; Lexington, Kentucky 40507. The finding from the schedule of findings and questioned costs for the year ended June 30, 2022 is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. 2022-001 Finding: Asbury Theological Seminary (ATS) failed to collect entrance counseling on a student before Title IV funds were disbursed to the institutional student account. Summary: The Seminary did not have a control in place to ensure timely completion of the entrance counseling. Institution Response: ATS uses an import tool through ED Connect to identify students who have completed entrance counseling. When the import is received, the financial aid staff manually enters the information into the Student Information System (Nexus) for each individual student. The student record in Nexus is then checked prior to the first Title IV loan disbursement for the student. The Department of Education introduced a new counseling item, Financial Awareness Counseling. While available, this form was imported and treated in the same manner as the other counseling forms (entrance/exit). Financial Awareness Counseling was completed for the student noted in the exception. The staff member reviewing the record mistakenly released loans, confusing the Financial Awareness Counseling as entrance counseling. ATS agrees with the audit finding. With the Department of Education terminating Financial Awareness Counseling, this helps avoid confusing the two documents. To prevent disbursing future Title IV loan funds to student accounts without the proper entrance counseling on file, a new process has been implemented. The Associate Director of Financial Aid, Mariah Shumate, will now cross check each new disbursement record prior to requesting funds from the Department of Education. Estimated Completion Date: September 22, 2022; Responsible manager: Mariah Shumate, Associate Director of Financial Aid

View Audit 50952

Finding 61873 (2022-001)

None 2022

Erskine College

SC

Reporting Student Financial Aid Eligibility

2022-001 NSLDS Reporting Planned Corrective Action: All withdrawals will be updated in NSLDS at the time the withdrawal is processed, and notification is made to the appropriate offices by the registrar. This has not been the case, and it has resulted in withdrawn students being overlooked when pr...

2022-001 NSLDS Reporting Planned Corrective Action: All withdrawals will be updated in NSLDS at the time the withdrawal is processed, and notification is made to the appropriate offices by the registrar. This has not been the case, and it has resulted in withdrawn students being overlooked when preparing the enrollment spreadsheet for uploading into NSLDS. Including the NSLDS reporting as part of the withdrawal process will ensure that all withdrawn students are reported in a timely manner to NSLDS. At the beginning of each term, the registrar will ensure that all returning students are correctly reported to NSLDS. We have seen an increase in students who return, and a more deliberate effort to report these students will ensure that they students are correctly reported to NSLDS. In the near future, the registrar plans to partner with the National Clearinghouse for enrollment reporting. This partnership will involve the use of a report generated from CAMS for reporting rather than a spreadsheet that is manually updated by the registrar. Person Responsible for Corrective Action Plan: Tracey Spires- Registrar Anticipated Date of Completion: June 2023

View Audit 58543

Finding 61859 (2022-006)

None 2022

University of Hawaii

HI

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding No. 2022-006: Return of Title IV Funds ? Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.063 ? Federal Pell Grant 84.268 ? Federal Direct Student Loans Questioned Costs: $140 Responsible Individual: Davileigh Nae`ole, Financial Aid Direc...

Finding No. 2022-006: Return of Title IV Funds ? Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.063 ? Federal Pell Grant 84.268 ? Federal Direct Student Loans Questioned Costs: $140 Responsible Individual: Davileigh Nae`ole, Financial Aid Director, UHMC Date Action Taken: November 1, 2022 Based on the auditor?s recommendation we will ensure determination of the withdrawal date for students who unofficially withdraw within 30-days after the end of the period of enrollment. Another staff member is being trained to assist with the calculation of R2T4. In addition, the R2T4s are now a process that is reviewed weekly. Based on the auditor?s recommendation we will remit the institutional portion of unearned aid to the appropriate Title IV program within the required 45-day time period. Another staff member is being trained to assist with the R2T4 calculations and R2T4?s are being reviewed weekly. These changes should ensure the timely return of unearned aid to the Title IV programs.

View Audit 56981

Finding 61858 (2022-005)

None 2022

University of Hawaii

HI

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

Finding No. 2022-005: Financial Aid Administration - Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.268 ? Federal Direct Student Loans Questioned Costs: $ - Responsible Individual: Anna Chamberlain, Financial Aid Manager, Windward Community Colle...

Finding No. 2022-005: Financial Aid Administration - Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.268 ? Federal Direct Student Loans Questioned Costs: $ - Responsible Individual: Anna Chamberlain, Financial Aid Manager, Windward Community College Date Action Taken: October 10, 2022 Reconciliation will now be done using SAS files that will automatically be sent from COD at the beginning of each month. This new process will be completed every 30 days and will produce a monthly report that will be saved in the office shared drive. A Standard Operating Procedure will be created for the new Loan Reconciliation process, and the Financial Aid Manager will be primarily responsible for this process with the Financial Aid Specialist trained as secondary in case of an absence.

View Audit 56981

Finding 61857 (2022-004)

None 2022

University of Hawaii

HI

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

Finding No. 2022-004: Financial Aid Administration ? Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.268 ? Federal Direct Student Loans Questioned Costs: $ - Responsible Individual: Jennifer Bradley, Financial Aid Manager, Kapi`olani Community Colle...

Finding No. 2022-004: Financial Aid Administration ? Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.268 ? Federal Direct Student Loans Questioned Costs: $ - Responsible Individual: Jennifer Bradley, Financial Aid Manager, Kapi`olani Community College Date Action Taken: March 2022 In early March 2022 the campus servers, held by the Center for Excellence in Learning, Teaching and Technology or CELTT, where all data was stored, went down and data was not recoverable. Documentation used as evidence is copy of real-time reports/transactions. All reconciliation documentation was stored on that server. Though reconciliation was done monthly, we were not able to provide evidence of 2 of the 3 sample months. After we were apprised of the campus servers, the Financial Aid Office created drives/folders in UH Enterprise Dropbox where we started to save our daily work, including reconciliation documentation. This commenced about March 10, 2022. We started using UH Enterprise Dropbox for Centralization processes in December 2020, thus expanded its use to include our office work/processes. On approximately March 14, 2022 CELTT was able to restore/recreate the servers and install the proper software to resume operations and store data. The campus servers have since been manually backed-up every-other-week. Additionally, CELTT is working on an automated process to back-up the campus servers on a weekly basis. They are awaiting hardware to complete this process. It is expected that the automated back-up will start in early 2023. Starting November 2022 and on at least a quarterly basis reconciliation documentation is transferred/saved to the campus server. This will assure that we have proper documentation of our reconciliation.

View Audit 56981

Finding 61856 (2022-003)

None 2022

University of Hawaii

HI

Questioned Costs Student Financial Aid Internal Control / Segregation of Duties

Finding No. 2022-003: Return of Title IV Funds - Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.063 ? Federal Pell Grant Program Questioned Costs: $670 Responsible Individual: Gregg Yoshimura, Financial Aid Director, Leeward Community College Dat...

Finding No. 2022-003: Return of Title IV Funds - Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.063 ? Federal Pell Grant Program Questioned Costs: $670 Responsible Individual: Gregg Yoshimura, Financial Aid Director, Leeward Community College Date Action Taken: September 2022 To ensure that Title IV Funds are returned no later than 45 days after the date of the institution?s determination that the student withdrew, the institution has updated its Return to Title IV procedure to add a step to confirm that all institution required returns have been processed and returned. Financial Aid Office staff will be assigned to review completed Return to Title IV calculations on a weekly basis to ensure that all institution required returns have been remitted to Federal Student Aid within the required time period.

View Audit 56981 Questioned Costs: $1

Finding 61854 (2022-002)

None 2022

University of Hawaii

HI

Questioned Costs Student Financial Aid Reporting

Finding No. 2022-002: Financial Aid Administration - Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.063 ? Federal Pell Grant 84.268 ? Federal Direct Student Loans Questioned Costs: $812 Responsible Individual: Heather Florindo, Financial Aid Manage...

Finding No. 2022-002: Financial Aid Administration - Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.063 ? Federal Pell Grant 84.268 ? Federal Direct Student Loans Questioned Costs: $812 Responsible Individual: Heather Florindo, Financial Aid Manager, Honolulu Community College Date Action Taken: Immediately Return of Title IV Funds Currently we have one staff member assigned to process all Return of Title IV calculations. The office is in the process of hiring additional staff to assist with the workload created by the Return of Title IV calculation process. Furthermore, all staff will receive additional training regarding the regulations of Return of Title IV. Lastly, a processing schedule will be created to ensure that calculations are done in a timely manner and in accordance with the requirements of Return of Title IV. Direct Student Loans Currently, one staff person is responsible for the monthly reconciliation of the Federal Direct Student Loans that have been processed. A schedule will be created so that all staff are aware of when the loan reconciliation should be done. Furthermore, all staff will be trained in the loan reconciliation process so that all staff are able to complete the monthly loan reconciliation if needed.

View Audit 56981 Questioned Costs: $1

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