Corrective Action Plans

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Management's Response: We concur. View of Responsible Officials and Corrective Action Plan. Return of Funds - The Campus Business Office and the Financial Aid Office met to review the untimely return of funds. We determined and immediately implemented a restructured process where the R2T4 speciali...
Management's Response: We concur. View of Responsible Officials and Corrective Action Plan. Return of Funds - The Campus Business Office and the Financial Aid Office met to review the untimely return of funds. We determined and immediately implemented a restructured process where the R2T4 specialist in financial aid will review student accounts that require R2T4 calculations on a weekly basis. The students will be posted to the shared database between Financial Aid and the Business Office. The dedicated weekly time will expedite the calculation process. The Business Office, as part of the updated process will continue to treat the R2T4 award adjustments as a priority. In addition to the existing process of end of month reconciliation and return of funds, a mid-month returning of funds was added and implemented. The dedicated weekly timeline to calculate, as well as the added mid-month return of funds, will ensure that we meet the required return of funds within the 45-day window. The offices will meet to review this updated process and make any additional changes should they be necessary to maintain compliance. Calculations - To ensure compliance with calculations processed timely, we will relieve the R2T4 specialist of other responsibilities so he can dedicate 100% of his time to calculate within the required timeframe. In addition, there will be additional staff assisting with calculations because the institution closes for a 10- day period which impacts the 30-day timeframe. This will ensure that all calculations are done. Implementation Date: 11/15/2023
Recommendation: We recommend that the University review its processes and internal controls to includes a review of all manual adjustment made within NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The err...
Recommendation: We recommend that the University review its processes and internal controls to includes a review of all manual adjustment made within NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The error was made while making manual corrections to prior year posting. The University formally document a policy and procedure that will require the review all manual edits made to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Mark Quistorf and Registrar’s office. Planned completion date for corrective action plan: March 31, 2024
Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained. Explanation of disagreement with audit finding: There is no disagreement w...
Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Bursar desk manual has been updated to include information regarding the notice required Direct Loan disbursements. Additionally, statements have been updated to include appropriate messaging when loads are disburses. The statements are sent at the time the disbursements are made. Name(s) of the contact person(s) responsible for corrective action: Michele Peterson Planned completion date for corrective action plan: 12/31/23
Condition: The University has not designated a Qualified Individual responsible for implementing and monitoring the University's information security program, nor does the University have a written information security program that addresses the six required minimum elements as required by the Gramm...
Condition: The University has not designated a Qualified Individual responsible for implementing and monitoring the University's information security program, nor does the University have a written information security program that addresses the six required minimum elements as required by the Gramm‐Leach Bliley Act (GLBA). Corrective Action: At the time that we replied to the question, our former Qualified Individual responsible for implementing and monitoring the Institution's information security program had left the organization a month previously. Upon reflecting on the significance of this position, I have elevated this role to a higher priority in the organization and named Darrin Burns, Director of ERP and IT, as Fielding’s Qualified Individual. In collaboration with Darrin and CIO Solutions, our MSP, we will draft the written information security program using the cybersecurity assessment results and recommendations as a starting point. In addition, we will ensure that the final document will include all six required minimum elements per Title IV regulations (16 CFR 314). Person Responsible For Corrective Action: Darrin Burns, Director of IT and ERP Anticipated Completion Date: December 31, 2024
Reporting – The College will review and update current procedures to ensure timely processing and monitoring of NSLDS reports. Internal reports will be run simultaneously to make sure all students are captured and their status is correctly reported. Anticipated Completion Date - January 31, 2024; ...
Reporting – The College will review and update current procedures to ensure timely processing and monitoring of NSLDS reports. Internal reports will be run simultaneously to make sure all students are captured and their status is correctly reported. Anticipated Completion Date - January 31, 2024; Responsible Contact Person for Planned Corrective Action - Carissa Davis, Director of Financial Aid
Reporting – The College will review and update reporting procedures to ensure the correct academic start dates and enrollment dates are submitted to the Department of Education’s COD system. Anticipated Completion Date - January 31, 2024; Responsible Contact Person for Planned Corrective Action - C...
Reporting – The College will review and update reporting procedures to ensure the correct academic start dates and enrollment dates are submitted to the Department of Education’s COD system. Anticipated Completion Date - January 31, 2024; Responsible Contact Person for Planned Corrective Action - Carissa Davis, Director of Financial Aid
View Audit 294656 Questioned Costs: $1
Return of Title IV Funds - The College will review and update current written policies and procedures to ensure the correct amount of days are used for the academic term in the return of Title IV funds calculation. Anticipated Completion Date - January 31, 2024; Responsible Contact Person for Plann...
Return of Title IV Funds - The College will review and update current written policies and procedures to ensure the correct amount of days are used for the academic term in the return of Title IV funds calculation. Anticipated Completion Date - January 31, 2024; Responsible Contact Person for Planned Corrective Action - Carissa Davis, Director of Financial Aid
Responsible Official: Cheryl Soper - Assistant Vice President for Financial Operations and Controller View of Responsible Officials: The University concurs with the auditors’ findings. UM-Dearborn is taking action to ensure that voluntary consent to participate in electronic transactions is obtained...
Responsible Official: Cheryl Soper - Assistant Vice President for Financial Operations and Controller View of Responsible Officials: The University concurs with the auditors’ findings. UM-Dearborn is taking action to ensure that voluntary consent to participate in electronic transactions is obtained for all enrolled students before allowing them access to electronic transactions within our student information systems. For enrolled students who choose not to participate, alternative written communication methods will be provided. In addition, OFAS is making updates to its business processes and controls to ensure that all students receive notice of their award offer, complete with a description, before any disbursement on a student’s account is made. After a comprehensive assessment of its operational schedule, OFAS has adjusted the timing of award offers to students and are working closely with the University's Information Technology Services to establish a hold process that will ensure a student receives notification before disbursements are made. Anticipated Completion Date: May 2024
Responsible Official: Cheryl Soper - Assistant Vice President for Financial Operations and Controller View of Responsible Officials: The University concurs with the auditors’ findings. UM-Dearborn is taking action to ensure that payments made to a student who did not begin attendance in a payment pe...
Responsible Official: Cheryl Soper - Assistant Vice President for Financial Operations and Controller View of Responsible Officials: The University concurs with the auditors’ findings. UM-Dearborn is taking action to ensure that payments made to a student who did not begin attendance in a payment period or period of enrollment are returned within 30 days after the date the University becomes aware the student did not begin attendance. The Return of Title IV program at UM-Dearborn now has the appropriate policies and procedures in place to mitigate risk. Office of Financial Aid and Scholarships (“OFAS”) staff members have been trained and have earned professional credentials to manage the program effectively. In addition, annual training will take place to review updates to rules, regulations, and internal processes. A quality review of the program is also being developed, where OFAS will sample student populations who have had aid canceled due to nonattendance, official withdrawals and unofficial withdrawals. Anticipated Completion Date: July 2024
Corrective Action Plan The College agrees with the finding. The primary factor for the delay was due to a one-time reporting issue extracting data from the student information system following an upgrade. The reporting issue has been resolved and data extraction has been returned to normal. Onc...
Corrective Action Plan The College agrees with the finding. The primary factor for the delay was due to a one-time reporting issue extracting data from the student information system following an upgrade. The reporting issue has been resolved and data extraction has been returned to normal. Once that issue was resolved and the report successfully sent to NCS, NCS replied that they were not able to automatically push the student data to NSLDS requiring a manual solution, by requesting an ad-hoc roster from NSLDS to complete the reporting. The College completed the manual feed within the same day it was requested from NCS on 7/19/2023. The College is aware of the timeline needed to report to NCS and NSLDS. With both one-time issues now resolved, the College does not expect to have delayed reporting in the future. Timeline for Implementation of Corrective Action Plan Implemented Fall 2023 Contact Person Lisa Shawney, Dean of Finance and Administration, Montserrat College of Art, Inc.
The current administration recognizes that the control environment over disbursements and refunds must be strengthened. The College will establish controls to ensure that the 30-day wait period for federal direct loans to first-time full-time borrowers will be adhered to. To this effect, we have wor...
The current administration recognizes that the control environment over disbursements and refunds must be strengthened. The College will establish controls to ensure that the 30-day wait period for federal direct loans to first-time full-time borrowers will be adhered to. To this effect, we have worked with our software provider and their consultant to ensure that the new system of record, JFA, is picking up the correct students and placing holds on FTFT student records to prevent early disbursement. Also, to ensure students are receiving the maximum subsidized loan amount prior to disbursing unsubsidized loans, a review of subsequent ISIR records has been set in place, and additional staff in have been hired so that they can assist in complying with federal law. Finally, the College will review and evaluate all policies and procedures related to the timely processing of refunds. We have proper audits and trained staff members in place to be sure that we are running refund reports once per week ensuring the timely processing of credit balances and verifying that past due balances aren’t being funded with Title IV aid.
The College believes that the documents were completed and sent to the thirty-seven individuals concerned, however due to the cyber breach were unable to provide the requested documents. The College recognizes the importance of substantiating the information and has always been able to substantiate ...
The College believes that the documents were completed and sent to the thirty-seven individuals concerned, however due to the cyber breach were unable to provide the requested documents. The College recognizes the importance of substantiating the information and has always been able to substantiate it in prior year audits. The College uses the National Student Clearinghouse (NSC) to report student information to the NSLDS and is working with their student information system to ensure accurate student detail is submitted to the NSC on a timely manner. The College has addressed the cyber breach by enhancing security and access for all users (students and employees), upgrading software such as improved firewalls and multi-factor authentication, upgrading equipment where needed and moved most applications to cloud-based providers for better security.
The College recognizes the importance of reporting FISAP information accurately and will incorporate additional review processes to ensure its completeness and accuracy in the future.
The College recognizes the importance of reporting FISAP information accurately and will incorporate additional review processes to ensure its completeness and accuracy in the future.
2023-004 – Student Financial Assistance Cluster – Special Tests and Provisions – NSLDS Enrollment Reporting Condition During testing, it was determined that six of the 20 students tested for enrollment status changes did not have those changes properly reflected within their NSLDS records. Recommend...
2023-004 – Student Financial Assistance Cluster – Special Tests and Provisions – NSLDS Enrollment Reporting Condition During testing, it was determined that six of the 20 students tested for enrollment status changes did not have those changes properly reflected within their NSLDS records. Recommendation We recommend that the College review its control policies to ensure that reporting is completed accurately and timely. Wherever possible, any technological errors discovered should be pursued with the responsible party in order to try to determine a cause, and a solution or preventative measure should be implemented to prevent future errors from occurring. Comments on the Finding The oversite has been acknowledged by management and we will try our hardest to make sure that the process is addressed. Actions Taken Starting October 15, 2023, the Registrar will review the error reports from NSLDS in a timely manner to make sure that issues are resolved. There are quarterly training or consultations with Ellucian to verify best practices. On January 23, 2024, we received notification from NSLDS that we have been removed from “G for Degree Status” so that all awards will be recognized instead of an G Status for awards. Starting February 2024, student samples will be taken from submissions to NSLDS to review for accuracy before submissions.
2023-003 – Student Financial Assistance Cluster – Special Tests and Provisions – Student Information Security Condition During testing, it was determined that the College’s written policies did not reflect one of the seven required elements. Recommendation We recommend that the College’s written pol...
2023-003 – Student Financial Assistance Cluster – Special Tests and Provisions – Student Information Security Condition During testing, it was determined that the College’s written policies did not reflect one of the seven required elements. Recommendation We recommend that the College’s written policies be updated to properly reflect all seven elements required. Comments on the Finding Management is aware of the oversite and has enacted the practice of the missing policy in FY24. They have also worked on a policy to take to the SCCC Board of Trustees for approval. Actions Taken The policy has been written, reviewed, and is planned to go to the SCCC Board of Trustees on March 4, 2024.
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Explanation of disagreement with audit finding: There ...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Student Financial Aid Office will add an additional step to the policy for verifying and reviewing student loan levels. In addition to reviewing loan level reports before the beginning of the academic year, we will also review loan levels after the census date of the first semester of the academic year. This added step will catch any changes that were made to student packaging up to the census date. Name(s) of the contact person(s) responsible for corrective action: David L Kumm, Executive VP CFO/COO Planned completion date for corrective action plan: 7/1/2023
View Audit 294279 Questioned Costs: $1
Management’s Corrective Action Plan Soka University acknowledges the finding and the recommendation regarding improving procedures. Finding 2023-001 - Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance After addressing the identified defic...
Management’s Corrective Action Plan Soka University acknowledges the finding and the recommendation regarding improving procedures. Finding 2023-001 - Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance After addressing the identified deficiency in our enrollment reporting process, a thorough evaluation was conducted to rectify the issue and prevent its recurrence. We recognized that alterations in students' academic plans, prompted by the COVID-19 pandemic, led to delays in fulfilling mandatory graduation requirements such as study abroad requirements, resulting in delays in posting study abroad grades to the Soka transcript. Consequently, during end-of-term degree audits by the Office of the Registrar, students with pending study abroad grades or incomplete grades in their final term were inadvertently not updated to a withdrawn status, thereby failing to trigger updates to the National Student Clearinghouse and subsequently National Student Loan Data System (NSLDS). In collaboration with the Office of the Registrar, robust internal controls have been implemented to mitigate this issue going forward. Following the conclusion of each term, the Registrar will generate a comprehensive report listing all students who have applied for degree completion. This report will be annotated to identify students who have fulfilled all degree requirements, enabling their degrees to be conferred promptly. Additionally, students with incomplete grades will be flagged, and their status will be promptly changed to withdrawn. In both scenarios, enrollment status updates will be transmitted to the clearinghouse and subsequently NSLDS. The Registrar will inform the Office of Financial Aid of graduates and students with updated statuses for NSLDS reporting, and Financial Aid will request an ad hoc enrollment request on NSLDS. To ensure accuracy, a manual spot-checking process will be conducted in NSLDS on 20% of the updated student records in NSLDS. Upon notification of completed incomplete grades, the Registrar will promptly update transcripts, review degree requirements, and confer degrees where applicable. Following this update, the Registrar will manually update the clearinghouse and ask the Office of Financial Aid to request an Ad hoc enrollment report on NSLDS, ensuring timely and accurate reporting. This manual request will be verified on NSLDS after the ad hoc report has been run. Students failing to meet degree requirements due to failed coursework and are enrolled to return in subsequent terms will not be updated to withdrawn status unless they fail to return as scheduled. These measures aim to enhance the integrity and accuracy of our enrollment reporting process, ensuring compliance with regulatory requirements and minimizing the risk of future deficiencies. Anticipated Completion Date: February 2024 Scott Brandos Director of Financial Aid Soka University of America 949-480-4048
Finding 374491 (2023-001)
Significant Deficiency 2023
Views of Responsible Officials and Planned Corrective Actions: The University agrees with this recommendation and will ensure that staff with reporting compliance responsibilities are appropriately trained during periods of transition.
Views of Responsible Officials and Planned Corrective Actions: The University agrees with this recommendation and will ensure that staff with reporting compliance responsibilities are appropriately trained during periods of transition.
Auditor Description of Condition and Effect. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. As a result of this co...
Auditor Description of Condition and Effect. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. As a result of this condition, Return of Title IV calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 less funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Auditor Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is reviewed by a second individual. Corrective Action. Upon discovery of the Return of Title IV Calculation error, the College went through and made corrections to all student accounts affected. To prevent a similar problem arising in the future, the College has developed a review process that will require an additional sign‐off for the total days to be used in the calculation. Responsible Person. Ruth Carlson, Director of Financial Aid. Anticipated Completion Date. July 24, 2023.
Finding 374446 (2023-001)
Significant Deficiency 2023
Finding 2023-001: Special Test and Provisions: Enrollment Reporting Context/Condition: Of the 37 students selected for enrollment reporting testing, 5 students within the sample were reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the College revie...
Finding 2023-001: Special Test and Provisions: Enrollment Reporting Context/Condition: Of the 37 students selected for enrollment reporting testing, 5 students within the sample were reported to NSLDS outside the maximum 60-day window. 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: Tammy Gibson, Registrar Planned Corrective Action: Additional dates will be added to the National Student Clearinghouse submission schedule to capture December graduates. In addition, Registrar's Office staff will be instructed to update individual student records, as needed, to account for changes outside of the submission schedule to avoid reporting outside of the maximum 60-day window. Anticipated Completion Date: December 8, 2023
Corrective Action Planned: The College has noted the issue and it has since been rectified and has re-ran the process to provide the proper effective dates for withdrawn students to the National Student Clearinghouse. The College does report to the National Student Clearinghouse every 30 days. The C...
Corrective Action Planned: The College has noted the issue and it has since been rectified and has re-ran the process to provide the proper effective dates for withdrawn students to the National Student Clearinghouse. The College does report to the National Student Clearinghouse every 30 days. The College has reviewed their policies and procedures to ensure proper reporting requirement procedures to NSC and NSLDS. Training has been provided to those responsible for manual adjustments to records having extenuating circumstances. Name(s) of Contact Person(s) Responsible for Corrective Action: Eric Dinsmore, Senior Director of Financial Aid Anticipated Completion Date: As of January 2024, withdrawal student status change effective dates have been corrected. The College has reviewed reporting policies and procedures and has provided training to responsible parties for manual reporting whenever extenuating circumstances occur. The College will implement any additional necessary changes in 2024 fiscal year.
Finding 374388 (2023-004)
Significant Deficiency 2023
Corrective Action Plan 2023-004: The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to package loans when there is an annual or aggregate loan limit reached. Completion Date: August 2023 Contact Person: Haley Wesley, Vice President of Enr...
Corrective Action Plan 2023-004: The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to package loans when there is an annual or aggregate loan limit reached. Completion Date: August 2023 Contact Person: Haley Wesley, Vice President of Enrollment Management & Marketing
View Audit 293985 Questioned Costs: $1
Management concurs with the recommendation. Berklee will review and enhance processes related to reporting key items to the COD System.
Management concurs with the recommendation. Berklee will review and enhance processes related to reporting key items to the COD System.
Management concurs with the recommendation. Berklee will review and enhance processes related to reporting key items to the COD System. The institution will also update key fields to accommodate changes during the awarding process to ensure they agree with records.
Management concurs with the recommendation. Berklee will review and enhance processes related to reporting key items to the COD System. The institution will also update key fields to accommodate changes during the awarding process to ensure they agree with records.
Management concurs with the recommendation. Going forward, there will be at least two reviews of the FISAP prior to the annual filing, including all updates, to better ensure complete and accurate completion prior to filing with the U.S. Department of Education.
Management concurs with the recommendation. Going forward, there will be at least two reviews of the FISAP prior to the annual filing, including all updates, to better ensure complete and accurate completion prior to filing with the U.S. Department of Education.
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