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Corrective Action Plans

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Williams College
MA
Student Financial Aid Reporting Eligibility
Management's View and Corrective Action Plan Finding 2022-001 - Non-Compliance with Timely and Accurate Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS): Grantor: U.S. Department of Education Program Name: Student Financial Assistance Cluster Award Names: Federa...
Management's View and Corrective Action Plan Finding 2022-001 - Non-Compliance with Timely and Accurate Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS): Grantor: U.S. Department of Education Program Name: Student Financial Assistance Cluster Award Names: Federal Pell Grant Program and Federal Direct Loan Program Award Year: 7/1/2021 - 6/30/2022 Assistance Listing Numbers: 84.063 and 84.268 Management agrees with the finding and in concurrence with the recommendations has developed the following corrective action plan: The Registrar?s Office will manually reconcile enrollment status after each submission to the National Student Clearinghouse (?NSC?) submission to ensure student enrollment changes are submitted completely and timely. Alan Hatton, the Senior Associate Registrar, is responsible and has implemented this corrective action plan in February of 2023. Signed and Acknowledged, Kath Dunlop, Registrar
View Audit 41300
Finding 50138 (2022-002)
Significant Deficiency 2022
Wheaton College
MA
Student Financial Aid Matching / Level of Effort / Earmarking
2022-002 Federal Perkins Loans Recordkeeping and Record Retention Finding: Based on inspection of 25 student files, it was noted that there were 2 files that did not contain original loan documents. Corrective Action Taken or Planned: The identified loans without corresponding loan documentation ori...
2022-002 Federal Perkins Loans Recordkeeping and Record Retention Finding: Based on inspection of 25 student files, it was noted that there were 2 files that did not contain original loan documents. Corrective Action Taken or Planned: The identified loans without corresponding loan documentation originated nearly twenty years ago. At this point in time much of activity in the Office of Student Financial Services was conducted via paper, which left the loan agreements vulnerable to misplacement during office location and staffing changes. In conjunction with the Controller?s office, the Office of Student Financial Services intends to review the Perkins portfolio to identify any additional missing documents and work to locate originals. In cases where this search is unsuccessful, the College will review and potentially remove these agreements from the Perkins portfolio. In addition, the College has recognized a need for additional staffing for continued monitoring in the Office of Student Financial Services and has hired someone for the position of Director of Financial Aid to support the Senior Director for Student Financial Services. Anticipated Completion Date: September 2023 Person(s) Responsible for Corrective Actions: Carla Minchello - Director of Financial Aid
View Audit 43391
Finding 50062 (2022-007)
Significant Deficiency 2022
State of North Carolina
NC
Student Financial Aid Subrecipient Monitoring Reporting
Enrollment Status Reporting Errors Department Name: Western Piedmont Community College Contact Name / Telephone Number of Person Responsible for CAP: Dr. Tou Vang - (828) 448-3178 The Enrollment Reporting schedule in the College registrar?s office has been updated to ensure that reporting of student...
Enrollment Status Reporting Errors Department Name: Western Piedmont Community College Contact Name / Telephone Number of Person Responsible for CAP: Dr. Tou Vang - (828) 448-3178 The Enrollment Reporting schedule in the College registrar?s office has been updated to ensure that reporting of student enrollment information occurs every month. Enrollment Reports will be shared with the Financial Aid Office to confirm monthly updates in NSLDS. This procedure will ensure that the College submits all student status changes on a monthly basis. Corrective action was completed on: November 7, 2022.
View Audit 53638
Finding 50061 (2022-006)
Significant Deficiency 2022
State of North Carolina
NC
Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring
Enrollment Status Reporting Errors Department Name: Lenoir Community College Contact Name / Telephone Number of Person Responsible for CAP: Shelia Wiggins, Director of Financial Aid - (252) 527-6223 To correct the enrollment status reporting issues, Lenoir Community College has implemented the foll...
Enrollment Status Reporting Errors Department Name: Lenoir Community College Contact Name / Telephone Number of Person Responsible for CAP: Shelia Wiggins, Director of Financial Aid - (252) 527-6223 To correct the enrollment status reporting issues, Lenoir Community College has implemented the following corrective actions: ? The Registrar's and Financial Aid Office will develop a process to ensure that information is reported to the NSLDS through the National Student Clearinghouse on time. ? The Registrar has been given access to the NSLDS to review enrollment information and status changes reported to NSLDS through the National Student Clearinghouse for the accuracy of records. ? The Registrar has received further training on the correct workflow for updating students' withdrawal statuses. ? The Registrar and Director of Financial Aid will work cohesively to ensure that the corrective actions are effective by pulling a sample of students' changes from NSLDS and reviewing them for accuracy. ? Steps will be taken to ensure continued training and education of the Registrar's and Financial Aid Offices staff on enrollment status reporting. The steps above will allow the College to monitor compliance as it relates to Enrollment Status reporting. Anticipated Completion Date: June 30, 2023.
View Audit 53638
Finding 50060 (2022-005)
Significant Deficiency 2022
State of North Carolina
NC
Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring
Enrollment Status Reporting Errors Department Name: Central Piedmont Community College Contact Name / Telephone Number of Person Responsible for CAP: Richard Pucine - (704) 330-6247 On September 2, 2022, the College Registrar?s Office corrected the enrollment status for the three students identified...
Enrollment Status Reporting Errors Department Name: Central Piedmont Community College Contact Name / Telephone Number of Person Responsible for CAP: Richard Pucine - (704) 330-6247 On September 2, 2022, the College Registrar?s Office corrected the enrollment status for the three students identified during the audit with an incorrect status change. The College?s Senior Registrar is implementing an internal audit process in November to ensure all students with enrollment status changes are accurately reported to the National Student Loan Data System (NSLDS). Anticipated Completion Date: Corrective Action was partially completed on September 2, 2022. Full completion is expected in November 2022 with the implementation of the internal audit process.
View Audit 53638
Finding 50019 (2022-001)
Significant Deficiency 2022
Mary Baldwin University
VA
Student Financial Aid
The University is modifying the withdrawal procedure to provide more specific rules and instructions related to R2T4 requirements and timeliness. Included in those procedures will be earlier recognition of COVID events which may allow the student to decline or keep Title IV funds if deemed COVID rel...
The University is modifying the withdrawal procedure to provide more specific rules and instructions related to R2T4 requirements and timeliness. Included in those procedures will be earlier recognition of COVID events which may allow the student to decline or keep Title IV funds if deemed COVID related. Those temporary requirements at times have caused MBU to exceed the 45-day window.
View Audit 49718
Finding 50012 (2022-001)
Significant Deficiency 2022
Chestnut Hill College
PA
Student Financial Aid Subrecipient Monitoring Eligibility
FINDING 2022-001: 84.007 Federal Supplemental Education Opportunity Grant, 84.033 Federal Work Study Program, 84.038 Federal Perkins Loans, 84.063 Federal Pell Grant Program, 84.268 Federal Direct Loan Program, 84.379 Teacher Education Assistance for College and Higher Education Grants Recommendatio...
FINDING 2022-001: 84.007 Federal Supplemental Education Opportunity Grant, 84.033 Federal Work Study Program, 84.038 Federal Perkins Loans, 84.063 Federal Pell Grant Program, 84.268 Federal Direct Loan Program, 84.379 Teacher Education Assistance for College and Higher Education Grants Recommendation: The College should perform and document an annual risk assessment to determine the College's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the College should have at least one risk statement aligned or referenced to each of the three required areas noted in the GLBA law at 16 CFR 314.4 (b). Finally, the College should identify and document at least one safeguard (i.e., control) for each of the risks identified and document in the risk assessment. Each control should be aligned or referenced to the risk(s) to which the safeguard applies. Action To Be Taken: The College will complete a GLBA risk assessment that addresses (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. The College will complete the assessment in accordance with the December 9, 2021 Federal Trade Commission (FTC) issued final regulations to amend the Standards for Safeguarding Customer Information, including ensuring the College?s written information security program includes the nine elements included in the FTC?s regulations. Responsible Individual for Corrective Action: Scott Seidman, Director of IT Services Anticipated Completion Date: June 15, 2023
View Audit 48720
Finding 49942 (2022-002)
Significant Deficiency 2022
San Juan College
NM
Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking
Management agrees with this finding to meet compliance with the 45 day return of Title IV funds. ? Financial Aid is running a weekly report to capture all students that have dropped/withdrawn from classes. At the end of the semester (fall, spring or summer), a report is run to identify withdrawals, ...
Management agrees with this finding to meet compliance with the 45 day return of Title IV funds. ? Financial Aid is running a weekly report to capture all students that have dropped/withdrawn from classes. At the end of the semester (fall, spring or summer), a report is run to identify withdrawals, failed, or incomplete grades to determine if a return of funds calculation is warranted. This became important with the impact of COVID-19 on students which caused disruptions and difficulty in managing course loads. Financial Aid processes had a built in assumption that failed grades were unearned but, in reviewing and updating our processes most failed grades are actually earned. The return of funds has traditionally been calculated with the assumption the student did not earn the failed grade so the mid-point of the term was used for last date of attendance. Financial Aid is updating processes based on actuals and will continue working with Learning on the most efficient methodology to determine if a student has earned a failed grade or has stopped attending during the semester. ? Financial Aid will generate a weekly report to identify student withdrawals utilizing a new reporting tool being implemented late 2021. With the enhanced reporting tool and changes in methodology and process?s, we fully anticipate the return of funds will be calculated and remitted to the Department of Education within the required time. ? The Financial Aid Office has communicated with the Vice-President of Learning about the necessity for proper reporting by faculty with regards to non-attendance reporting and last date of attendance. ? Timeline: Management has already implemented the corrective actions. ? Mindi Schrum, Sr. Director and/or Greg Gallegos, Assistant Director will oversee the implementation of these.
View Audit 43710
Cowley County Community College
KS
Questioned Costs Student Financial Aid
2022-001 RETURN OF FUNDS Condition: There were two students in our sample of return of funds that were not completed timely. The Department of Education requires that all determinations of a potential return of funds be completed within 30 days of the withdrawal date. Criteria: The Department o...
2022-001 RETURN OF FUNDS Condition: There were two students in our sample of return of funds that were not completed timely. The Department of Education requires that all determinations of a potential return of funds be completed within 30 days of the withdrawal date. Criteria: The Department of Education requires that all determinations of a potential return of funds be completed within 30 days of the withdrawal date. Cause: There was confusion on implementing the new 49% rule. These students were determined initially to meet this new rule, but later were determined to still be under the old rules, causing a late calculation. Effect: Amounts were not remitted back to the Department of Education timely. Perspective: Staff had not yet received adequate training on new 49% rule. Once training was received staff went back and corrected return of fund calculations. Recommendation: We recommend that all students who withdraw from all classes that were awarded Title IV funds, be completed within 30 days of withdrawal date. Views of Responsible Officials and Planned Corrective Actions: The College agrees with this finding. Staff have attended webinars for the rules regarding return of funds and now have a more accurate understanding of when the calculation is required.
View Audit 42100 Questioned Costs: $1
Finding 49756 (2022-005)
Significant Deficiency 2022
Hennepin County Minnesota
MN
Allowable Costs / Cost Principles Eligibility Student Financial Aid § 200.303
Subject: Hennepin County?s 2022 Corrective Action Plan Finding# 2020-005?Eligibility Program: Foster Care Title IV-E (ALN 93.658) Type of Finding: Significant Deficiency in Internal Control over Compliance Condition: While we were able to test manual compensating controls over activities allowed ...
Subject: Hennepin County?s 2022 Corrective Action Plan Finding# 2020-005?Eligibility Program: Foster Care Title IV-E (ALN 93.658) Type of Finding: Significant Deficiency in Internal Control over Compliance Condition: While we were able to test manual compensating controls over activities allowed or unallowed, allowable costs/cost principles and eligibility, we were not able to review and test the automated application controls and the related ITGCs within the MAXIS and SSIS systems that reside within the State of Minnesota, but are utilized by the County, to determine whether the system controls are adequately designed and implemented and operating effectively. Hennepin County?s Corrective Action Planned in Response to Finding: Hennepin County will encourage the State to provide an independent audit of the design and implementation of MAXIS and SSIS system controls for the benefit of all counties. Hennepin County Employee Responsible for the CAP: Andra Roethler Planned Completion Date for CAP: December 31, 2023
View Audit 51481
Finding 49745 (2022-005)
Significant Deficiency 2022
Delaware State University
DE
Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking
2022-005 Student Financial Aid Cluster ? CFDA No. 84.268 ? Need Base Calculation Recommendation: We recommend that the University review the inputs of the calculation of need to ensure the non-need-based financial assistance is not included in need-based amounts. Explanation of disagreement with aud...
2022-005 Student Financial Aid Cluster ? CFDA No. 84.268 ? Need Base Calculation Recommendation: We recommend that the University review the inputs of the calculation of need to ensure the non-need-based financial assistance is not included in need-based amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Financial Aid (OFA) has updated the packaging parameters for all scholarships in Ellucian Banner. For FY23 and forward, the full awards will be counted as estimated financial assistance and will not replace the EFC in students? need calculation. OFA will run reports throughout the awarding cycle, to identify students who are over awarded or overbudgeted; students? Federal and/or institutional resources will be adjusted accordingly. Name(s) of the contact person(s) responsible for corrective action: Executive Director of Financial Aid, Dorothy Fultz Planned completion date for corrective action plan: February 2023
View Audit 49440
Finding 49741 (2022-006)
Significant Deficiency 2022
Delaware State University
DE
Student Financial Aid Reporting Significant Deficiency
2022-006 Student Financial Assistance Cluster ? CFDA Nos. 84.063 and 84.268 ? Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the Univ...
2022-006 Student Financial Assistance Cluster ? CFDA Nos. 84.063 and 84.268 ? Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar?s Office will update policies, procedures and reporting practices to ensure timely submission to both the National Student Clearinghouse and the National Student Loan Database. Name(s) of the contact person(s) responsible for corrective action: Registrar, Jackie K. Brockington, Jr. Planned completion date for corrective action plan: July 2023
View Audit 49440
Finding 49739 (2022-008)
Significant Deficiency 2022
Delaware State University
DE
Questioned Costs Student Financial Aid Significant Deficiency
2022-008 Student Financial Assistance Cluster ? Federal Assistance Listing Nos. 84.007, 84.063, and 84.268 - Outstanding Refund Checks Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior...
2022-008 Student Financial Assistance Cluster ? Federal Assistance Listing Nos. 84.007, 84.063, and 84.268 - Outstanding Refund Checks Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior to the 240-day deadline. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Report alerts and process has been in place as of November 2022. We have strengthened our processes. Name(s) of the contact person(s) responsible for corrective action: Executive Director of Student Accounts, Carold Boyer-Yancy. Planned completion date for corrective action plan: June 2023
View Audit 49440 Questioned Costs: $1
Finding 49738 (2022-007)
Significant Deficiency 2022
Delaware State University
DE
Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties
2022-007 Student Financial Assistance Cluster ? Federal Assistance Listing Nos. 84.007, 84.063, and 84.268 ? Credit Balances Recommendation: We recommend that the University reevaluate its process to refund student credit balances that arose from Title IV funds within 14 days. Explanation of disagre...
2022-007 Student Financial Assistance Cluster ? Federal Assistance Listing Nos. 84.007, 84.063, and 84.268 ? Credit Balances Recommendation: We recommend that the University reevaluate its process to refund student credit balances that arose from Title IV funds within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Refunds are being processed every 14 days in accordance with federal guidelines. We have strengthened our policies. Name(s) of the contact person(s) responsible for corrective action: Executive Director of Student Accounts, Carold Boyer-Yancy. Planned completion date for corrective action plan: December 2022
View Audit 49440
Finding 49661 (2022-004)
Material Weakness 2022
Michigan State University
MI
Student Financial Aid Matching / Level of Effort / Earmarking Eligibility
Finding Number: 2022-004 Condition: The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Planned Corrective Action: The University?s new financial aid module does not have the capability to send emails. ...
Finding Number: 2022-004 Condition: The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Planned Corrective Action: The University?s new financial aid module does not have the capability to send emails. That functionality does exist in the University?s new student information system. Consequently, effective for Fall 2022 semester, the Office of Financial Aid partnered with Office of the Controller ? Student Accounts to generate emails on a weekly basis to any student who receives a disbursement of Title IV funds. By May 1, 2023 the University will create similar procedures to identify disbursements of Parent PLUS loans and then coordinate with Office of the Controller - Student Accounts to leverage the student information system to send notifications to parent borrowers. Contact person responsible for corrective action: Marshall Rumsey, Senior Associate Director, Office of Financial Aid Anticipated Completion Date: Completed September 8, 2022 (student), to be completed May 1, 2023 (parent)
View Audit 42191
Finding 49649 (2022-006)
Significant Deficiency 2022
Michigan State University
MI
Questioned Costs Student Financial Aid Significant Deficiency
Finding Number: 2022-006 Condition: The University did not obtain the correct tax return as part of the verification process. Planned Corrective Action: The University? initial understanding was that the new financial aid management database extracted the required data from the uploaded documents. ...
Finding Number: 2022-006 Condition: The University did not obtain the correct tax return as part of the verification process. Planned Corrective Action: The University? initial understanding was that the new financial aid management database extracted the required data from the uploaded documents. When it was discovered that this was not the case, the Office of Financial Aid disabled this functionality in the system and began reviewing all uploaded documents in January 2022 to confirm that they are the required documents. Contact person responsible for corrective action: Marshall Rumsey, Senior Associate Director, Office of Financial Aid Anticipated Completion Date: Completed January 1, 2022
View Audit 42191 Questioned Costs: $1
Finding 49648 (2022-005)
Material Weakness 2022
Michigan State University
MI
Questioned Costs Student Financial Aid Eligibility
Finding Number: 2022-005 Condition: The University awarded incorrect Pell awards to certain students based on the Pell Payment and Disbursement Schedule. Planned Corrective Action: The University?s new financial aid module was modified to use the census date for Pell recalculation rather than an arb...
Finding Number: 2022-005 Condition: The University awarded incorrect Pell awards to certain students based on the Pell Payment and Disbursement Schedule. Planned Corrective Action: The University?s new financial aid module was modified to use the census date for Pell recalculation rather than an arbitrary number of days into the term that did not match the University policy. The correction for this finding was implemented prior to aid being disbursed for the Fall 2022 semester. Contact person responsible for corrective action: Cheryl Whitman, Associate Director, Office of Financial Aid Anticipated Completion Date: Completed August 31, 2022
View Audit 42191 Questioned Costs: $1
Finding 49647 (2022-003)
Material Weakness 2022
Michigan State University
MI
Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking
Finding Number: 2022-003 Condition: The University used incorrect or incomplete data in the return of Title IV calculations. Planned Corrective Action: The new financial aid management database made incorrect R2T4 calculations and prevented manual adjustments to the calculations. The calculations ar...
Finding Number: 2022-003 Condition: The University used incorrect or incomplete data in the return of Title IV calculations. Planned Corrective Action: The new financial aid management database made incorrect R2T4 calculations and prevented manual adjustments to the calculations. The calculations are now done externally to the system and fixes and workarounds have been implemented to allow for the correct processing of R2T4 calculations. As of the Fall 2022 semester R2T4 calculations were being performed in the required timeframe. University personnel were not aware there was a shorter deadline (30 days versus 45 days) to return funds if the student had not begun attendance. Therefore, effective March 15, 2023, funds were being returned within 30 days for students for whom there is no confirmed attendance. Beginning with the fall 2022 semester, the Registrar?s Office has initiated procedures to confirm attendance/academic activity for courses that are dropped. This allows the University to identify whether adjustments need to be made to Pell grants before an R2T4 calculation is performed, and to determine if an R2T4 calculation is required or if all aid is to be returned for non-attendance. The withdrawal process itself has been modified to more clearly identify the withdrawal date. Contact person responsible for corrective action: Matthew Lyth, Financial Aid Officer Anticipated Completion Date: Completed March 15, 2023
View Audit 42191 Questioned Costs: $1
Finding 49646 (2022-001)
Material Weakness 2022
Michigan State University
MI
Student Financial Aid Material Weakness Reporting
Finding Number: 2022-001 Condition: The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Planned Corrective Action: The University implemented a new administrative database for student academic records. The provided tool for ex...
Finding Number: 2022-001 Condition: The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Planned Corrective Action: The University implemented a new administrative database for student academic records. The provided tool for extracting enrollment data did not perform as expected and hampered the school?s ability to provide the required data to the National Student Clearinghouse. The Registrar?s Office resolved its data collection issues and is now submitting the data to NSLDS via the Clearinghouse on the required timeline. Contact person responsible for corrective action: Becky Keogh, Senior Associate Registrar Anticipated Completion Date: Completed November 15, 2022
View Audit 42191
Finding 49626 (2022-001)
Significant Deficiency 2022
Lesley University
MA
Questioned Costs Student Financial Aid Eligibility
Finding ? Return of Funds Condition Out of forty students selected for testing, nine students were under awarded Pell grants based on their EFC and COA. This is not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The University begins to award students...
Finding ? Return of Funds Condition Out of forty students selected for testing, nine students were under awarded Pell grants based on their EFC and COA. This is not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The University begins to award students prior to the new Pell Grant schedule release in late March. In April our software provider, Ellucian, releases an update for us to upload with the new Pell Grant schedule. This update was completed but some of the Pell Grants that had been packaged prior to the update were not reprocessed and repackaged with the new Pell Grant amounts. This error was due to a loss of personnel that had previously managed the reprocessing of the Pell Grants. Management has already reprocessed any students for 2022-23 to ensure correctness of Pell awards for the current year. Additionally, management has adopted new step by step procedures in writing to assist with the reprocessing/repackaging of Pell Grant awards to ensure that proper practices will be followed on a forward basis. Management is also in the process of reviewing 21-22 Pell awards and will disburse any shortfalls by December 31, 2022 to impacted students. Responsible Official: Frank Mullen Completion Date: 10/26/2022
View Audit 42506 Questioned Costs: $1
Finding 49522 (2022-001)
Significant Deficiency 2022
Western Michigan University
MI
Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking
Finding Number: 2022-001 Condition: The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Planned Corrective Action: While the information was reported on time to the National Student Clearinghouse, there were unresolved error re...
Finding Number: 2022-001 Condition: The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Planned Corrective Action: While the information was reported on time to the National Student Clearinghouse, there were unresolved error reports that prevented three of these students from being reported to NSLDS within the 60 days. For the other five students, there was a delay within the clearinghouse which was an isolated incident. We will continue to follow up with the clearinghouse and NSLDS for students that are not updated and staff responsible for reconciling error reports will notify a supervisor if they are unable to complete the task within two weeks so additional assistance can be provided. Contact person responsible for corrective action: Carrie Cumming, Registrar Anticipated Completion Date: 3/01/2023
View Audit 47967
Finding 49521 (2022-005)
Significant Deficiency 2022
Western Michigan University
MI
Student Financial Aid Eligibility Reporting
Finding Number: 2022-005 Condition: The University improperly reported the students that withdrew within the COD System as a result of the COVID-19 national emergency. Planned Corrective Action: The Student Financial Aid (SFA) office agrees with the finding that certain withdrawn students were impr...
Finding Number: 2022-005 Condition: The University improperly reported the students that withdrew within the COD System as a result of the COVID-19 national emergency. Planned Corrective Action: The Student Financial Aid (SFA) office agrees with the finding that certain withdrawn students were improperly reported in COD because of the COVID-19 national emergency. SFA evaluated its R2T4 procedures and strengthened its internal controls by discontinuing the practice of automatically adding the COVID indicator to students who withdrew. Contact person responsible for corrective action: Lana Greaves, Senior Associate Director, Student Financial Services Anticipated Completion Date: 4/15/2023
View Audit 47967
Finding 49520 (2022-003)
Material Weakness 2022
Western Michigan University
MI
Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking
Finding Number: 2022-003 Condition: The University did not return funds in accordance with 34 CFR 668.22 which states, 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 inst...
Finding Number: 2022-003 Condition: The University did not return funds in accordance with 34 CFR 668.22 which states, 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 aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs. Planned Corrective Action: The Student Financial Aid (SFA) office agrees with the finding that all the funds calculated to be returned for a student were not billed back. Management acknowledges that the deficiency was due to an oversight. The isolated occurrence was corrected on 01-13-2023. The unsubsidized loan amount of $3,558 was returned, and the change was reflected in COD. SFA awarded the student institutional aid of $3,558 to compensate for the error. In addition, the 60% withdrawal date was corrected, R2T4 calculations were performed, the funds were returned, and SFA awarded the students institutional aid to compensate for the errors. Step-by-step procedure for calculating the R2T4 60% withdrawal date were created and before the beginning of each aid year, Client Services and the Associate Director of Compliance will determine the 60% withdrawal dates for each term. Contact person responsible for corrective action: Lana Greaves, Senior Associate Director, Student Financial Services Anticipated Completion Date: 04/15/2023
View Audit 47967 Questioned Costs: $1
Finding 49519 (2022-002)
Material Weakness 2022
Western Michigan University
MI
Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties
Finding Number: 2022-002 Condition: The University initiated certain returns of Title IV funds after the required timing. Planned Corrective Action: The Student Financial Aid (SFA) office agrees with the finding that certain Return of Title IV funds were initiated after the required time. SFA evalua...
Finding Number: 2022-002 Condition: The University initiated certain returns of Title IV funds after the required timing. Planned Corrective Action: The Student Financial Aid (SFA) office agrees with the finding that certain Return of Title IV funds were initiated after the required time. SFA evaluated its R2T4 procedures in May 2022 and strengthened its internal controls by: 1. Reviewing reports of withdrawn students on a daily basis. 2. Weekly reporting of R2T4 and LDA students and calculations with two levels of approvals. 3. Holding weekly meetings and performing self-assessments to verify completion and accuracy of R2T4 calculations. Contact person responsible for corrective action: Lana Greaves, Senior Associate Director, Student Financial Aid Anticipated Completion Date: 10/23/2022
View Audit 47967
Fordham University
NY
Student Financial Aid Matching / Level of Effort / Earmarking Eligibility
The accurate reporting of campus-level OPEID is required by federal regulation for Title IV students, and although the reporting provides data on Title IV programs, it does not prompt repayment on loans or have any impact on a student's federal aid eligibility. Pursuant to a root-cause analysis cond...
The accurate reporting of campus-level OPEID is required by federal regulation for Title IV students, and although the reporting provides data on Title IV programs, it does not prompt repayment on loans or have any impact on a student's federal aid eligibility. Pursuant to a root-cause analysis conducted by the University, it was determined (and ultimately acknowledged) by the servicer that it had failed to follow established protocols prior to transmitting this information to NSLDS, which led to this finding. The information provided by the University was accurate and consistent with the methodology we use regularly to transmit information to this servicer. The U.S. Department of Education requires independent compliance audits for third-party servicers that help colleges and universities administer Title IV programs and, as part of our on-going due diligence, we reviewed the attestation opinion issued by the independent auditor, who noted no issues with respect to this particular compliance requirement or the servicer?s ability to comply with it. The University has discussed with the third-party servicer its process for submitting Campus-Level information to the NSLDS, and changes are being made by the servicer to ensure its own compliance with the methodology for transmitting data to the NSLDS. The University is also undertaking a detailed review of this servicer?s performance to mitigate the risk of recurrence.
View Audit 45944
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