Corrective Action Plans

Finding 384689 (2023-002)

Significant Deficiency 2023

Columbia College

MO

Student Financial Aid Matching / Level of Effort / Earmarking Significant Deficiency

2023-002 Disbursement of Title IV Funds (Significant Deficiency) Criteria: An institution must disburse during the current payment period, with certain qualifying exceptions, the amount of Title IV, HEA program funds that a student enrolled at the institution, or the student’s parent, is eligible to...

2023-002 Disbursement of Title IV Funds (Significant Deficiency) Criteria: An institution must disburse during the current payment period, with certain qualifying exceptions, the amount of Title IV, HEA program funds that a student enrolled at the institution, or the student’s parent, is eligible to receive for that payment period, 34 CFR 668.164(b)(1). Condition: During our testing, we noted three instances in a sample of 26 students in which Direct Loan awards were not disbursed to the student during the payment period. Qualified exceptions were not met and the three students received disbursements for the 2022-2023 academic year on August 14, 2023. Action Taken: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the staff attend internal and external training sessions regularly. Currently, disbursements are processed at least 3 times a week. The Office of Financial Aid works diligently to ensure all funds are fully disbursed by the end of each semester. Responsible Party: Lola Kennedy, Senior Director of Financial Aid Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) Expected date of correction: January 2024

View Audit 297799

Finding 384688 (2023-001)

Material Weakness 2023

Columbia College

MO

Student Financial Aid Material Weakness Reporting

2023-001 Special Reporting – Fiscal Operations Report and Application to Participate (FISAP) (Material Weakness) Criteria: As a Campus-Based Program participant, the College is required to submit an accurate FISAP yearly by October 1. The information reported on the FISAP is used to determine the s...

2023-001 Special Reporting – Fiscal Operations Report and Application to Participate (FISAP) (Material Weakness) Criteria: As a Campus-Based Program participant, the College is required to submit an accurate FISAP yearly by October 1. The information reported on the FISAP is used to determine the school’s Campus Based Program funding for the upcoming award year as well as report Campus‑Based Program expenditures for the prior award year. The College is required to submit a Fiscal Operations Report plus other information required; the information must be accurate and shall be submitted on the form at the time specified, 34 CFR 674.19(d)(2). Condition: During our review of the College’s FISAP it was determined that tuition and fee revenue was overstated and Pell amount reported was understated. Action Taken: We concur with this finding. Staff made a “change request” to the US Department of Education (USDOE) to adjust the FISAP. Once the “change request” was approved by the USDOE, we edited the FISAP report to appropriately reflect the audited numbers. It is important to note that the FISAP is due by September 30th, and the USDOE allows institutions until December 15th to adjust the figures. Our audited financial statements are due no later than September 30th, which normally allows time to ensure that the figures on the FISAP are reconciled to the ones on the audited financial statements. Nevertheless, if the audited statements are not completed by the September 30th deadline, we will make sure that any adjusting entries to the FISAP are made by the final date of December 15th. Responsible Party: Lola Kennedy, Senior Director of Financial Aid Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) Expected date of correction: February 2024

View Audit 297799

Finding 384673 (2023-001)

Significant Deficiency 2023

Bristol Community College

MA

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

Corrective Action Plan To ensure that there are no further instances of late return of title IV funds due to withdrawals, the financial aid office has updated their process. As a quality assurance measure, every withdrawal processed by the Registrar’s office will be sent to three individuals in the ...

Corrective Action Plan To ensure that there are no further instances of late return of title IV funds due to withdrawals, the financial aid office has updated their process. As a quality assurance measure, every withdrawal processed by the Registrar’s office will be sent to three individuals in the FA office- Director, Associate Director, and Withdrawal Coordinator. After the final withdrawal report from the Registrar’s office has been processed each semester, all students will be reviewed individually by Director, Associate Director, and Coordinator. The manual review process will ensure that all reported students have been appropriately reviewed and processed within the required timeframe. This updated process will eliminate the human error associated with the finding. Timeline for Implementation of Corrective Action Plan Implemented Fall 2023 Contact Person: Alaina Marcotte, Director Financial Aid

View Audit 297771

Finding 384582 (2023-003)

Material Weakness 2023

Metro Technology Center

OK

Student Financial Aid Reporting Material Weakness

Finding Summary: Various discrepancies were noted in the National Student Loan Data System. Responsible Individuals: Alicia Smith, Director of Financial Aid Corrective Action Plan: We have worked to implement a process to quickly update student enrollment status in all financial aid systems to ensur...

Finding Summary: Various discrepancies were noted in the National Student Loan Data System. Responsible Individuals: Alicia Smith, Director of Financial Aid Corrective Action Plan: We have worked to implement a process to quickly update student enrollment status in all financial aid systems to ensure proper reporting. Anticipated Completion Date: July 1, 2024

View Audit 297658

Finding 384579 (2023-002)

Significant Deficiency 2023

Metro Technology Center

OK

Student Financial Aid Reporting Significant Deficiency

Finding Summary: One financial aid disbursement tested was not made within the allowable 15 day period. Responsible Individuals: Alicia Smith, Director of Financial Aid Cari Wilburn, Director of Finance Corrective Action Plan: We have worked together in both departments to ensure proper reporting on...

Finding Summary: One financial aid disbursement tested was not made within the allowable 15 day period. Responsible Individuals: Alicia Smith, Director of Financial Aid Cari Wilburn, Director of Finance Corrective Action Plan: We have worked together in both departments to ensure proper reporting on the financial aid systems and quick disbursements of all funds. Anticipated Completion Date: July 1, 2024

View Audit 297658

Finding 384532 (2023-001)

Significant Deficiency 2023

Fairfield University

CT

Student Financial Aid Special Tests & Provisions Reporting

Finding No. 2023-001 – Significant Deficiency and Noncompliance: Special Tests and Provisions – Enrollment Reporting Corrective Action The corrective action that will be taken is a graduates only enrollment report will be supplied to the National Student Clearinghouse (NSC) by the Registrar’s Offi...

Finding No. 2023-001 – Significant Deficiency and Noncompliance: Special Tests and Provisions – Enrollment Reporting Corrective Action The corrective action that will be taken is a graduates only enrollment report will be supplied to the National Student Clearinghouse (NSC) by the Registrar’s Office on a consistent schedule of submission within 60 days of each graduation period. Persons Responsible for Corrective Action The corrective action plan will be completed by Walter Rankin, Vice Provost for Graduate Continuing and Professional Studies and Danielle Quilligan, University Registrar. Completion Date Initial corrective action was completed by Lynn Kohrn, University Registrar and Allison Henderson, Assistant Registrar in October, 2023 with the submission of a graduates only enrollment report to the third-party service provider NSC. A schedule for consistent submissions of a graduates only enrollment report has already been provided to the NSC.

View Audit 297643

Finding 384358 (2023-001)

Material Weakness 2023

Eastern University

PA

Questioned Costs Student Financial Aid Material Weakness

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Determining the last date of academically related activity for Return of Title IV Funds was identified as a finding from last audit year (2021-2022). A Department of Education review was completed and once this was done and deter...

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Determining the last date of academically related activity for Return of Title IV Funds was identified as a finding from last audit year (2021-2022). A Department of Education review was completed and once this was done and determined that we made the proper adjustments for 21-22, a complete and detailed review for 22-23 to correct any incorrect R2T4’s was completed. This resulted in untimely returns but has since been resolved. Person Responsible for Corrective Action Plan: Andrea Ruth, Director of Financial Aid Anticipated Date of Completion: August 2023

View Audit 297474

Finding 384354 (2023-001)

Significant Deficiency 2023

University of Denver

CO

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

Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated fed...

Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: As of January 2024, the University implemented a monthly process for the coordinated review of stale-dated checks. After the close of each month, the Accountant II and Business Analyst in the Controller’s Office prepares a report of stale-dated checks and sends the report to the Assistant Director of Student Accounts and the Student Accounts Business Analyst in University Financial Services. These staff members identify federal funds to be returned to the Department of Education. The Office of Student Accounts works with the Office of Financial Aid to ensure funds are returned. This process has addressed any backlog of checks, and the monthly process keeps the University current in processing stale-dated checks and returning funds in a timely manner. Name of the contact person responsible for corrective action: Andrew Cullen, Associate Vice Chancellor, Finance and Janet Burkhardt, Assistant Vice Chancellor, University Financial Services. Planned completion date for corrective action plan: Effective immediately.

View Audit 297469 Questioned Costs: $1

Finding 384353 (2023-002)

Significant Deficiency 2023

University of Denver

CO

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

Condition: During our testing, we noted two of the Perkins files in which the MPN was not retained on file for loans with outstanding balances. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: The University determined th...

Condition: During our testing, we noted two of the Perkins files in which the MPN was not retained on file for loans with outstanding balances. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: The University determined there are a total of 39 Perkins loans with missing MPNs. Of these, 6 loans are with 3rd party collection agencies, 19 are paid in full and 14 are in repayment. For these 39 loans, the University determined that alternative documentation such as exit counseling and repayment records has been retained. The Perkins Assignment and Liquidation Guide (p.4), ED tells schools to collect alternative documentation, explain the reason the note is missing and affirm the school has searched all records for each loan missing documentation. Due to the discontinuance of the Perkins loan program, no new MPNs will be issued. Name of the contact person responsible for corrective action: Andrew Cullen, Associate Vice Chancellor, Finance and Janet Burkhardt, Assistant Vice Chancellor, University Financial Services. Planned completion date for corrective action plan: Corrective action plan completed in August 2023.

View Audit 297469

Finding 384322 (2023-003)

Significant Deficiency 2023

Erikson Institute

IL

Cash Management Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Finding 2023-003: Cash Management The Institute had three instances of return of funds that resulted in excess cash for Federal Direct Student Loans ranging from $94 to $46,049 during the period of September 19, 2022 through November 29, 2022. In these situations, the excess cash, being less than ...

Finding 2023-003: Cash Management The Institute had three instances of return of funds that resulted in excess cash for Federal Direct Student Loans ranging from $94 to $46,049 during the period of September 19, 2022 through November 29, 2022. In these situations, the excess cash, being less than one percent of total prior year drawdowns, were not returned within a seven day tolerance period. Corrective Action Plan A Student Bursar was hired in November 2022 and onboarding included comprehensive federal funds cash management training with an outside consultant. A review of cash management policies in place was conducted at that time and monitoring procedures and reconciliations were enhanced to eliminate excess cash. Contact Person Christine Frankhauser Controller cfrankhauser@erikson.edu Anticipated Completion Date January 2023

View Audit 297439

Finding 384321 (2023-002)

Significant Deficiency 2023

Erikson Institute

IL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

Finding 2023-002: Enrollment Reporting For two out of four students tested (50%) who withdrew from the Institute, the students’ enrollment status reported to the National Student Loan Data System (NSLDS) did not match the institution’s records. Corrective Action Plan The Director of Research, Reg...

Finding 2023-002: Enrollment Reporting For two out of four students tested (50%) who withdrew from the Institute, the students’ enrollment status reported to the National Student Loan Data System (NSLDS) did not match the institution’s records. Corrective Action Plan The Director of Research, Registration, & Records, who oversees the Registration & Records office has taken steps to ensure timely and accurate reporting moving forward. In summer 2023, a new full-time Registrar was hired to oversee the office. Additionally, Erikson has updated the functioning of its student information system in ways that are compatible with timely and accurate reporting. Changes to the system have been tested and implemented. Lastly, Erikson created a new Business Analyst position and is in the process of hiring to oversee administration and maintenance of the student information system in ways that will continue to facilitate timely reporting and data integrity. Contact Person Leanne Beaudoin Ryan, PhD Director of Research, Registration, & Records lbeaudoinryan@erikson.edu Anticipated Completion Date Updates to processes and procedures were completed in September 2023. Transition from outsourced staffing to the newly-created position is expected by May 2024.

View Audit 297439

Finding 384307 (2023-002)

Significant Deficiency 2023

Desert Community College District

CA

Student Financial Aid Reporting Significant Deficiency

The District concurs with the finding. The District will establish new procedures to verify student Enrollment Reporting Roster data before submission. This will allow the district to identify discrepancies and make necessary adjustments and to ensure accurate information is reflected in the NSLDS w...

The District concurs with the finding. The District will establish new procedures to verify student Enrollment Reporting Roster data before submission. This will allow the district to identify discrepancies and make necessary adjustments and to ensure accurate information is reflected in the NSLDS website.

View Audit 297438

Finding 384306 (2023-001)

Significant Deficiency 2023

Desert Community College District

CA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

The District concurs with the finding. The District will establish procedures such as monthly reconciliation for return to Title IV calculations to identify the funds that need to be returned and ensure that funds are returned within 45 days.

View Audit 297438

Finding 384289 (2023-002)

None 2023

Trinity Bible College and Graduate School

ND

Questioned Costs Student Financial Aid Reporting

2023-002 FISAP Reporting Planned Corrective Action: Trinity Bible College and Graduate School has implemented policies and procedures to address the gaps in reporting Perkins information related to the FISAP report. A new director of Financial Aid has been put in place to help ensure proper reporti...

2023-002 FISAP Reporting Planned Corrective Action: Trinity Bible College and Graduate School has implemented policies and procedures to address the gaps in reporting Perkins information related to the FISAP report. A new director of Financial Aid has been put in place to help ensure proper reporting. Person Responsible for Corrective Action Plan: Executive Vice President Vaughn Jordan, Director of Financial Aid Wesley Brothers, and Coordinator of Financial Aid Shannon Pool. Anticipated Date of Completion: CAP has already been implemented regarding this issue.

View Audit 297426

Finding 384249 (2023-005)

Significant Deficiency 2023

Manhattan School of Music

NY

Student Financial Aid

The school will continue to effectively streamline processes regarding leaves of absences and withdrawals and data entry into the Student Information System (SIS). In part, the separation dates will be manually entered with the National Student Clearinghouse (NSC). To note, the school permits studen...

The school will continue to effectively streamline processes regarding leaves of absences and withdrawals and data entry into the Student Information System (SIS). In part, the separation dates will be manually entered with the National Student Clearinghouse (NSC). To note, the school permits students to take leave of absences (LOA) for up to two semesters, which is greater than the Federal Student Aid (FSA) allows (180 days). The Registrar’s Office codes students on leave with a separation date in our SIS, the student will also be coded as such with NSC. If the student does not return from a LOA after 180 days (6 months), the NSC student record will be updated to a withdrawn status effective one day before or one day after the leave began as recommended by NSC.

View Audit 297400

Finding 384248 (2023-004)

Material Weakness 2023

Manhattan School of Music

NY

Student Financial Aid

The School’s Finance and Financial Aid departments will more closely coordinate the vetting of the numbers before entering on FISAP. The two departments will schedule annual meeting to discuss and review the numbers.

View Audit 297400

Finding 384247 (2023-003)

Significant Deficiency 2023

Manhattan School of Music

NY

Student Financial Aid Matching / Level of Effort / Earmarking

Monthly reconciliation reports resumed in a more detailed manner effective December 2022 with the arrival of the new Senior Associate Director of Financial Aid. The process was a collaborative effort between the Senior Associate Director and MSM’s Financial Aid consultant through August 2023 after w...

Monthly reconciliation reports resumed in a more detailed manner effective December 2022 with the arrival of the new Senior Associate Director of Financial Aid. The process was a collaborative effort between the Senior Associate Director and MSM’s Financial Aid consultant through August 2023 after which the function resides with the Senior Associate Director.

View Audit 297400

Finding 384226 (2023-003)

None 2023

Hannibal-Lagrange University

MO

Reporting Questioned Costs Student Financial Aid

Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A representative from the Registrar’s Office will meet monthly with a representative of the Financial Aid Office to provide spot-checks and quality assurance to the student information uploaded to NSLDS. St...

Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A representative from the Registrar’s Office will meet monthly with a representative of the Financial Aid Office to provide spot-checks and quality assurance to the student information uploaded to NSLDS. Student information is uploaded to the NSLDS monthly, so this should provide another layer of assurance each time information is submitted. An internal deadline and standing meeting will be established to ensure consistent compliance. Person Responsible for Corrective Action Plan: Joseph D. Garner III, Registrar Anticipated Date of Completion: The new process will begin April, 2024.

View Audit 297334

Finding 384209 (2023-002)

Significant Deficiency 2023

Illinois Wesleyan University

IL

Student Financial Aid Special Tests & Provisions Significant Deficiency

2023-002 Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program),...

2023-002 Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program), 93.364 (Nursing Student Loans) Recommendation: We recommend that the University designate an individual to oversee the information security function and work to update the University’s written security program to ensure compliance with all the standards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Illinois Wesleyan University will designate an individual to be the Information Security Officer. The information security policy will be updated as applicable for GLBA standards. Name(s) of the contact person(s) responsible for corrective action: David Myron Planned completion date for corrective action plan: Updates for the information security policy will be made on an as-needed basis for applicable changes. The Information Security Officer will be named in Spring 2024. If the Department of Education has questions regarding this plan, please call Scott Seibring at (309) 556-3096.

View Audit 297294

Finding 384203 (2023-001)

Significant Deficiency 2023

Illinois Wesleyan University

IL

Student Financial Aid Reporting Significant Deficiency

2023-001 Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program),...

2023-001 Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program), 93.364 (Nursing Student Loans) Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: When a graduation has been confirmed outside of the normal timeframe due to later grade reporting, the Assistant Registrar will include the Director of Financial Aid and the Associate Director of Financial Aid in an email along with the standard process of notifying the Associate Registrar. The Associate Director of Financial Aid will go directly to NSLDS and enter the graduation date in NSLDS. The Associate Registrar will continue the normal reporting process with the Clearinghouse but this will alleviate challenges that come when the Associate Registrar is resolving discrepancies and can’t report the graduation immediately. Name(s) of the contact person(s) responsible for corrective action: Scott Seibring Planned completion date for corrective action plan: This process will be implemented starting with the Spring 2024 semester.

View Audit 297294

Finding 384172 (2023-002)

Significant Deficiency 2023

Capitol Technology University

MD

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

Finding 2023-002 Significant Deficiency over Special Tests and Provisions - Enrollment Reporting The University acknowledges that there was 1 out of the 14 students selected that the change in , - 0 enrollment status was reported by the University more than 60 days after the enrollment status change...

Finding 2023-002 Significant Deficiency over Special Tests and Provisions - Enrollment Reporting The University acknowledges that there was 1 out of the 14 students selected that the change in , - 0 enrollment status was reported by the University more than 60 days after the enrollment status change. Effective with the Student Enrollment Roster received from NSLDS in 2024 the business practice has changed with the implementation of the modernized NSLDS Professional Access website. Upon receipt of the Student Enrollment Roster, the file is updated by an updated algorithm using data from the University’s CRM, Jenzabar. The resulting spreadsheet is uploaded to NSLDS for verification and submittal. The accepted records are updated in NSLDS' database and are removed from the resulting spreadsheet produced by NSLDS. The records that error-out are listed on the resulting spreadsheet. This file is maintained for audit purposes. To ensure accurate enrollment status updates, the records listed on the resulting spreadsheet are updated manually on the NSLDS website. The manual entries are updated in real-time. In addition, the University is updating enrollment status changes manually upon receipt of Action Forms initiated by the student instead of waiting for the next Enrollment Report from NSLDS. This should correct the issue where a change in student status was not captured by NSLDS and reasonably ensure compliance with Federal status. Contact Person: Kim Wittler, AVP, Enrollment and Financial Aid Completion Date: March 1, 2024

View Audit 297272

Finding 384147 (2023-003)

Significant Deficiency 2023

Lyon College

AR

Student Financial Aid Significant Deficiency

Corrective Action: Since all full-time students receive institutional aid, they must all have an aid package in our system in order for us to disburse that aid to their account. All new students would need to be presented with an award offer in order to make decisions about any financial responsib...

Corrective Action: Since all full-time students receive institutional aid, they must all have an aid package in our system in order for us to disburse that aid to their account. All new students would need to be presented with an award offer in order to make decisions about any financial responsibilitiy created by enrolling at Lyon College, so I believe all students received award offers. Going forward, the new (manual) digital file system will be more familiar to us and the learning curve less steep. Our normal process will include placing a copy of the award letter in every student's digital file. We will add a process to be run after the census date of each semester - as well as at later dates in the semester - to make sure that every full-time student and every student with federal aid has a digital file that includes a copy of their award offer, even those who submit a FAFSA after classes have begun for the semester. Proposed Completion Date: June 30, 2024

View Audit 297270

Finding 384146 (2023-002)

Significant Deficiency 2023

Lyon College

AR

Student Financial Aid Reporting Significant Deficiency

Corrective Action: The "Timely Reporting" issue resulted from a misunderstanding in the Registrar's Office regarding the requirements of what had to be reported and by when. We have discussed this issue with that office's personnel and established procedures designed to prevent it from happening i...

Corrective Action: The "Timely Reporting" issue resulted from a misunderstanding in the Registrar's Office regarding the requirements of what had to be reported and by when. We have discussed this issue with that office's personnel and established procedures designed to prevent it from happening in the future. The "Funds Not Returned Timely" reflects continued improvements resultig from policies already established to enhance compliance with attendance reporting and tracking of those reports by the Registrar and Financial Aid Offices. The College will continue to reinforce procedures for active monitoring of those reports by these two offices. In particular, the process of evaluating whether students who are on the two-week absence report in any one class are in fact at risk of falling out of enrollment status overall. Proposed Completion Date: June 30, 2024

View Audit 297270

Finding 384139 (2023-006)

Significant Deficiency 2023

Concordia University, St. Paul

MN

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

deral Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their Title IV compliance report is completed timely so that the University can perform the necessary due diligence they need to p...

deral Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their Title IV compliance report is completed timely so that the University can perform the necessary due diligence they need to perform. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will communicate with our third party servier to understand when they believe their SSAE 18 report will be issued. If it will be late, we will coordinate with them to perform the necessary testing to ensure we can perform the due diligence. Name of the contact person responsible for corrective action: Financial Aid Director Amanda McCaughan Planned completion date for corrective action plan: June 30, 2024

View Audit 297264

Finding 384133 (2023-005)

Significant Deficiency 2023

Concordia University, St. Paul

MN

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit findi...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have taken all of the findings and placed it on our risk register. Each Wednesday, we have a vulnerability call with our VCISCO. Over the last year, we have reduced the number of vulnerabilities in our systems. Over the last month, we have begun to work on the items on our risk register. We have a working session set for April 8, 2024 to update all findings that relate to the policies that were not to standard. For the other items, we will work on our weekly calls to set up the necessary SOPs to address the deficiencies. Name of the contact person responsible for corrective action: Director of Computer Services of Network Jonathan Breitbarth Planned completion date for corrective action plan: June 30, 2024

View Audit 297264

Corrective Action Plans

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