Corrective Action Plans

Finding 1165459 (2025-002)

Material Weakness 2025

Cottey College

MO

Student Financial Aid

Condition: The College did not accurately timely and accurately complete refund calculations for 1 out of 4 students (25%) tested. We consider this finding to be a significant deficiency in relation to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section I...

Condition: The College did not accurately timely and accurately complete refund calculations for 1 out of 4 students (25%) tested. We consider this finding to be a significant deficiency in relation to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2024-005. Corrective Action Plan: Cynthia Lawrence in the Business Office will conduct a secondary full review of each R2T4 form completed by Hannah Masters, the student’s account statement and balance in Jenzabar, the withdrawal form supplied by the Registrar, the withdrawal date reported in Jenzabar by the Registrar, and any last date of attendance documentation provided by faculty or the Registrar. If any discrepancies are identified, Cynthia will notify both Hannah Masters and the Registrar’s team by email, outlining the issue. Once corrections are submitted, Cynthia will review the updated materials to ensure accuracy and compliance. Responsible Person for Correction Action Plan: Hannah Masters, Executive Director of Financial Aid and Student Accounts Cynthia Lawrence, Accounts Receivable / Staff Accountant Implementation Date for Corrective Action Plan: October 15, 2025

View Audit 376177

Finding 1165458 (2025-001)

Material Weakness 2025

Cottey College

MO

Student Financial Aid

Condition: During our testing of thirty-seven student files, we noted two individuals (5.4%) that were not properly awarded Direct Loans. Corrective Action Plan: Twice each Fall and Spring semester, Hannah Masters will request an updated report of enrolled student year status from the Registrar, Cha...

Condition: During our testing of thirty-seven student files, we noted two individuals (5.4%) that were not properly awarded Direct Loans. Corrective Action Plan: Twice each Fall and Spring semester, Hannah Masters will request an updated report of enrolled student year status from the Registrar, Chayna Penney. She will compare these statuses to the year-in-school information reported by students on their FAFSA, which is housed in the PowerFAIDS software. If any discrepancies are identified, Hannah will submit a FAFSA correction on behalf of the student, import the correction into PowerFAIDS, and review and recalculate the student’s financial aid. The student will then be repackaged appropriately, and an updated aid offer will be generated. Finally, Hannah will notify the student by email regarding the changes made to their account and will connect them with the Business Office and Registrar’s Office for any additional follow-up. This process was completed on October 1, 2025, for the Fall 2025 term, and a second review for Fall 2025 is scheduled for December 1, 2025. Responsible Person for Correction Action Plan: Hannah Masters, Executive Director of Financial Aid Chayna Penney, Registrar Implementation Date for Corrective Action Plan: October 01, 2025

View Audit 376177

Finding 1165448 (2025-002)

Material Weakness 2025

Westmoreland County Community College

PA

Student Financial Aid Subrecipient Monitoring Cash Management

Finding 2025-002: Student Financial Aid Cluster – Reporting View of Responsible Officials and Planned Corrective Action: Root Cause Errors occurred because the data file transmitted from Anthology to COD did not consistently include the correct student information. It is not yet clear whether the is...

Finding 2025-002: Student Financial Aid Cluster – Reporting View of Responsible Officials and Planned Corrective Action: Root Cause Errors occurred because the data file transmitted from Anthology to COD did not consistently include the correct student information. It is not yet clear whether the issue arises from configuration problems, system design limitations, or both. Planned Corrective Action and Responsible Officials • Procedure review and update. The Financial Aid Office will review and revise procedures to ensure accurate, timely, and complete reporting to COD, including pre-submission and post-submission checks. • System-to-COD file analysis with Anthology. In partnership with Anthology's support and managed services teams, the College will: o o o Analyze how COD reporting files are created within Anthology. Identify why certain student data elements are not being transmitted correctly. Implement configuration changes or other system-level fixes to ensure accurate and complete reporting. • Enhanced manual validation until issues are resolved. If the file creation process is determined to be working "as designed" but still does not meet regulatory expectations, Financial Aid staff will perform manual review and correction of COD files prior to submission, and will monitor error and rejection reports from COD for follow-up. As with Finding 2025-001, the Vice President for Student Affairs and the Director of Financial Aid share responsibility for ensuring these corrective actions are implemented and sustained commencing on the date set forth above.

View Audit 376153

Finding 1165447 (2025-001)

Material Weakness 2025

Westmoreland County Community College

PA

Student Financial Aid § 200.303

Finding 2025-001: Student Financial Aid Cluster – Eligibility View of Responsible Officials and Planned Corrective Action: Root Cause Shortcomings in the Anthology cost-of-attendance and auto-packaging/repackaging logic prevented consistent, accurate calculations based on enrollment level and other ...

Finding 2025-001: Student Financial Aid Cluster – Eligibility View of Responsible Officials and Planned Corrective Action: Root Cause Shortcomings in the Anthology cost-of-attendance and auto-packaging/repackaging logic prevented consistent, accurate calculations based on enrollment level and other eligibility factors. These gaps increased the amount of manual intervention required by Financial Aid staff and contributed to human error. Planned Corrective Action and Responsible Officials • Policy and procedure updates. The Financial Aid Office will review and revise policies and procedures to ensure that the calculation of cost of attendance and awarding of aid are fully aligned with federal regulations and institutional policy. • System configuration and process review with Anthology. Working with Anthology's support and managed services teams, the College will: o Analyze the current cost-of-attendance component and related packaging logic. o Re-configure system settings or implement automated workarounds to ensure that: ■ Cost of attendance is calculated correctly based on enrollment level and other required factors. ■ Auto-packaging and repackaging correctly award and adjust aid when a student's enrollment level or other eligibility factors change. Strengthened manual review until system stability is confirmed. Despite vendor assurances that the product would reduce manual effort, two levels of Financial Aid staff will manually review students' cost-of-attendance calculations and awards each term until the SIS demonstrates consistent accuracy over multiple audit cycles. Commencing on the date set forth above, the Vice President for Student Affairs, in coordination with the Director of Financial Aid, will oversee implementation of the above corrective actions and report progress to the President and the Board.

View Audit 376153

Finding 1165434 (2025-001)

Material Weakness 2025

Coast Community College District

CA

Student Financial Aid Material Weakness Reporting

Views of Responsible Officials and Corrective Action Plan The District submits the file with the required enrollment information to the National Student Clearinghouse (NSC) two weeks after the start of each term and subsequently on a monthly basis. Part of the reporting process includes running SFRT...

Views of Responsible Officials and Corrective Action Plan The District submits the file with the required enrollment information to the National Student Clearinghouse (NSC) two weeks after the start of each term and subsequently on a monthly basis. Part of the reporting process includes running SFRTMST, a baseline process in Ellucian Banner, the District’s Enterprise Resource Planning system, to calculate or update a student’s enrollment time status, which is the date when a change occurred in the enrollment of a student due to either registering in a class(es) or withdrawing from a class(es). The enrollment time status date is included in the enrollment file submitted to NSC. NSC then submits the enrollment information to the National Student Loan Data System (NSLDS). The discrepancy identified for the nine students was between a withdrawal date in Banner versus the enrollment time status date reported to NSC/NSLDS, which was the Banner calculated date. Because of the timing of when the SFRTMST process was ran, some students’ enrollment time status date did not match the registration activity date/enrollment effective date in Banner. After conducting research using the Ellucian Customer Center, the District identified a resolution to address this issue and has already implemented it for Fall 2025. To ensure that the students’ enrollment time status date reported to NSC/NSLDS matches the students’ effective date of their registration activity in Banner, the District activated the Calculate Time Status (Indicator) in SOATERM, a Banner setup, for Fall 2025 and will do so for all terms moving forward. Per Ellucian, when this indicator is set to “Y” a dynamic time status calculation will take place. The District verified that this process works. The issue has been resolved. In addition, the dates for the nine students were corrected in NSLDS. It is important to note that this issue has had no financial impact on the District. The students have been disbursed the correct amount of financial aid. The calculation of financial aid to be disbursed is not based on the enrollment dates reported to NSC and NSLDS.

View Audit 376138

Finding 1165416 (2025-001)

Material Weakness 2025

Buena Vista University

IA

Student Financial Aid

Finding Reference Number 2025-001 Contact Person: Mindi Thompson, Registrar Current Status: When a student withdrew from a course or two during a term but still remained a part-time student for that term, those withdrawn courses were being counted in the enrollment intensity levels by the student in...

Finding Reference Number 2025-001 Contact Person: Mindi Thompson, Registrar Current Status: When a student withdrew from a course or two during a term but still remained a part-time student for that term, those withdrawn courses were being counted in the enrollment intensity levels by the student information system for the purpose of generating enrollment level reporting for NSC-NSLDS. Views of Responsible Officials & Planned Corrective Action: Enrollment reports are generated directly from our student information system and we identified a system setting that controls whether or not withdrawn courses should be included in these reports. That setting has been updated and the Registrar is manually reviewing all records for students that withdrew from one or more courses during the term before finalizing and submitting the reports to NSC-NSLDS. Records affected during the 2024-25 academic year were all manually reviewed and updated by the Registrar at NSLDS. Staff will review software system settings regularly to ensure they stay set the correct way for future reporting. Anticipated Completion Date: Prior records with issues have already been corrected and ongoing monitoring is taking place.

View Audit 376103

Finding 1165395 (2025-001)

Material Weakness 2025

Union College

KY

Student Financial Aid Special Tests & Provisions

2025-001 - Student Financial Assistance Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work-Study Program (c) Federal Perkins Loan (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education Grants (...

2025-001 - Student Financial Assistance Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work-Study Program (c) Federal Perkins Loan (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education Grants (TEACH Grants) (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Criteria: 34 CFR 668.162 (d) states: Under the heightened cash monitoring payment method, an institution must credit a student’s ledger account for the amount of Title IV, HEA program funds that the student or parent is eligible to receive, and pay the amount of any credit balance due before the institution submits a request for funds. Condition: We tested 40 students and credit balances were not paid in a timely manner for 8 students (20%). We consider this condition to be a material weakness for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical Sampling was not used in making sample selections. Responsible Persons: Andra Butler and Jessica Justice Corrective Action Plan: Management agrees with the finding. Management has already implemented corrective actions to ensure that credit balances caused by federal funds are refunded prior to those federal funds being requested by the University. Financial Aid notifies the Business Office when all postings are complete. The Business Office then runs a disbursement roster and refunds those students with credit balances. Once the refunds have been delivered to the students, the Business Office draws in the funds per the disbursement roster totals. The disbursement roster is retained as support for the drawdown amount Implementation Date: Fall 2025

View Audit 376003

Finding 1165389 (2025-003)

Material Weakness 2025

Kansas Wesleyan University and Foundation

KS

Student Financial Aid Significant Deficiency

Incorrect Pell Calculations Condition: The University did not properly award Pell for the Summer term under the new enrollment intensity calculation requirements. Planned Corrective Action: This is an isolated error on the part of the Financial Aid Office staff. In review of the new Pell grant calcu...

Incorrect Pell Calculations Condition: The University did not properly award Pell for the Summer term under the new enrollment intensity calculation requirements. Planned Corrective Action: This is an isolated error on the part of the Financial Aid Office staff. In review of the new Pell grant calculations staff members misinterpreted summer Pell regulations. During implementation of the new system software, Pell calculations were believed to be automatic. In subsequent years staff members will review policies for summer programs, participate in training sessions, seminars and workshops, to ensure they understand the rules, regulations and guidelines as they apply to enrollment intensity regulations, in order to manually adjust Pell amounts for part-time students. Person Responsible for Corrective Action Plan: Amanda McLaughlin, Assistant Vice President of Financial Aid; Miranda Lumley Associate Director of Financial Aid Anticipated Date of Completion: Fall of 2025 prior to end of the term and awarding aid for upcoming semesters in the 2025-26 award year.

View Audit 376000

Finding 1165331 (2025-001)

Material Weakness 2025

University of Cincinnati

OH

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Condition: The University did not have controls in place to ensure that the required due diligence review was completed in the last two-year period related to the current established contract. Planned Corrective Action: In order to ensure that the terms of the consumer accounts offered through UC’s ...

Condition: The University did not have controls in place to ensure that the required due diligence review was completed in the last two-year period related to the current established contract. Planned Corrective Action: In order to ensure that the terms of the consumer accounts offered through UC’s Tier 1 banking agreement are not inconsistent with the best financial interest of students who choose to open an account, UC Campus Services will, at a minimum, every 2 years, beginning October 2025: a. Conduct a due diligence review to ascertain whether the fees imposed under the current agreement are consistent with or below prevailing market rates. a. This will be accomplished by downloading and comparing “consumer schedule of fees” documents from UC’s current provider as well as several local competitors (e.g. US Bank, Fifth Third Bank, Chase Bank, Superior Credit Union). b. Ensure that termination provisions are maintained in the active agreement. These provisions are listed in the current agreement under Exhibit G. 4. (g). (1). In addition, the university will organize a Title IV compliance working group to meet monthly to review any communications or new requirements published by the U.S. Department of ED, State of Ohio, or other regulatory agencies. This core working group will be comprised of members of the Student Financial Aid Office, the Office of the Bursar, and the Office of the Controller, the three offices primarily responsible for awarding, disbursing, and drawing down funds related to the Title IV programs. This group will be responsible for communicating any changes to institutional responsibilities to other university partners who may need to review or revise policies and procedures based on the regulatory changes. Contact person responsible for corrective action: Neal Stark for the specific remedy for the due diligence review, Leigh Jackson for the compliance working group. Anticipated Completion Date: 10/31/2025 and every 2 years thereafter

View Audit 375925

Finding 1165325 (2025-003)

Material Weakness 2025

Rocky Mountain College

MT

Special Tests & Provisions Student Financial Aid Significant Deficiency

Finding 2025-003: In order to ensure proper compliance with the return of Title IV Funds, the CFO and Controller have updated the return to Title IV (R2T 4) workbook to include the correct rounding method per federal regulation and the Federal Student Aid Handbook. Documentation of each calculation ...

Finding 2025-003: In order to ensure proper compliance with the return of Title IV Funds, the CFO and Controller have updated the return to Title IV (R2T 4) workbook to include the correct rounding method per federal regulation and the Federal Student Aid Handbook. Documentation of each calculation will now include evidence of rounding verification as part of the R2T4 process. Additionally, the Controller will obtain annual training on current Department of Education requirements, including proper rounding and calculation methodologies.

View Audit 375900

Finding 1165315 (2025-001)

Material Weakness 2025

Rocky Mountain College

MT

Reporting Internal Control / Segregation of Duties Special Tests & Provisions

Finding 2025-001: In order to ensure proper compliance with reporting student enrollment statuses to the National Student Loan Data System, the CFO, Controller, and Director of Student Records will familiarize themselves with federal reporting deadlines and create an improved internal system to moni...

Finding 2025-001: In order to ensure proper compliance with reporting student enrollment statuses to the National Student Loan Data System, the CFO, Controller, and Director of Student Records will familiarize themselves with federal reporting deadlines and create an improved internal system to monitor and report student enrollment changes on a timely basis. The CFO, Controller, and Director of Student Records will explore enhanced monitoring controls such as designating a second reviewer to verify that all files were transmitted and accepted by NSC within required timeframes and implementing an internal tracking log to record the submission and confirmation dates for each roster file.

View Audit 375900

Finding 1165288 (2025-002)

Material Weakness 2025

Mount Saint Mary's University

CA

Student Financial Aid Reporting Significant Deficiency

Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-002 Condition: For 5 of 25 students tested in the sample, the student’s status was reported late to the National Student Loan Data System (NSLDS). The sample was not a statistically valid sample. Corre...

Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-002 Condition: For 5 of 25 students tested in the sample, the student’s status was reported late to the National Student Loan Data System (NSLDS). The sample was not a statistically valid sample. Corrective Action Plan : The Registrar’s office generates enrollment reports every three (3) weeks and they are sent to NSLDS. These reports allow for frequent degree of enrollment reporting to correct this type of error. These changes are in place and have taken effect immediately. Name(s) of Contact Person(s) Responsible for Corrective Action: Rocio De Leon, Registrar Anticipated Completion Date: Immediately Joy E. Brathwaite, MBA MSA Vice President for Finance and Administration Dated: 12/4/2025

View Audit 375827

Finding 1165283 (2025-001)

Material Weakness 2025

Mount Saint Mary's University

CA

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

Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-001 Condition: The University did not have evidence or documentation available to support the control/review process for return of Title IV calculations. Corrective Action Plan : The University will co...

Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-001 Condition: The University did not have evidence or documentation available to support the control/review process for return of Title IV calculations. Corrective Action Plan : The University will continue to review and adhere to our procedures for refunding awards, and the Financial Aid office will formally document the weekly review of the Return of Title IV funds. Name(s) of Contact Person(s) Responsible for Corrective Action: La Royce Housley, Director of Financial Aid Anticipated Completion Date: Immediately Joy E. Brathwaite, MBA MSA Vice President for Finance and Administration Dated: 12/4/2025

View Audit 375827

Finding 1165241 (2025-001)

Material Weakness 2025

University of Dallas

TX

Special Tests & Provisions Student Financial Aid Reporting

Corrective Action Plan: The University will continue to improve upon Enrollment Reporting as well as continue with all of the changes previously identified and corrected. The University will ensure that the Received Date by NSLDS is within the 60 day compliance reporting requirement. With respect to...

Corrective Action Plan: The University will continue to improve upon Enrollment Reporting as well as continue with all of the changes previously identified and corrected. The University will ensure that the Received Date by NSLDS is within the 60 day compliance reporting requirement. With respect to the reporting of Program Lengths in error, the University took steps to update the processes associated with that activity subsequent to the issuance of the report containing the prior year Single Audit finding 2024-001. Upon consultation with the Office of the Provost and the appropriate Deans of the affected Colleges, the program length for the Master’s programs at the University was updated to two (2), for those programs between 30 and 36 credit hours in length; and three (3) academic years, for those whose minimum credit hours exceeds 36 credit hours, which will meet a reasonable progression to such degree. The Office of Registrar updated all such programs to reflect the decision for the University in November 2024. The students noted in the 2025-001 finding ceased to be active prior to the updated process’ implementation and were excluded from the reporting population. All activity contained in the sample selection for changes after the implementation date were handled in accordance with the regulations. One of those students reenrolled and the Program Length was updated to correctly reflect the student’s new program. The University will continue to monitor this area for any future discrepancies. Responsible Parties: The University has identified the Registrar – Paula Brown along with the Director of the Office of Financial Aid – James Hubener as the responsible parties to ensure continued monitoring of the activity on these types of items to ensure timely and accurate reporting to NSLDS. Estimated Completion Date: November 30, 2024

View Audit 375648

Finding 1165239 (2025-001)

Material Weakness 2025

Barton County Community College

KS

Special Tests & Provisions Student Financial Aid Period of Performance

SIGNIFICANT DEFICIENCY 2025-001 Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Return to Title IV Condition Of the 37 students tested for Return to Title IV procedures, 2 were determined to have had errors in their calculation. Recommendat...

SIGNIFICANT DEFICIENCY 2025-001 Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Return to Title IV Condition Of the 37 students tested for Return to Title IV procedures, 2 were determined to have had errors in their calculation. Recommendation We recommend that the College review and update its policies to ensure that accurate Return to Title IV calculations are completed. Comments on the Finding For the issue with an institutional charge incorrectly considered in the R2T4 calculation, this was due to a Federal Direct Parent PLUS Loan that was processed and a refund to the parent. Only seven of these loans were processed in the aid year of 2024-25, and there were no other R2T4 situations that involved a Federal Direct Parent PLUS Loan. The refund to the parent was shown at the top of the Banner form while student refunds show at the bottom of the Banner form. Due to the rarity of these loans being included in the calculation and the variation of where this charge is shown in Banner, this was missed. Barton personnel are now aware of where to look for this in these very rare cases. For the situation where the incorrect starting date was identified, there was human error when that was entered. Barton does have a quality assurance process to double check all dates on the Banner withdrawal form, and the R2T4 calculation spreadsheet, however, this review will now extend to checking the enrollment dates in a second Banner form. Action Taken Since the 2024-25 aid year was still open, both instances were corrected. Barton’s Director of Financial Aid has made all personnel aware of the issues and has revised the quality assurance review to watch for these issues.

View Audit 375642

Finding 1165237 (2025-001)

Material Weakness 2025

Remington College

TX

Student Financial Aid Eligibility

The Institution has reviewed the details of the finding and determined the error to be due to human error and the responsibility of the Institution. Subsequent to the audit, the Institution refunded $350 in 2023-2024 Federal Pell Grant program funds on behalf of student #20 (VR). In addition the Ins...

The Institution has reviewed the details of the finding and determined the error to be due to human error and the responsibility of the Institution. Subsequent to the audit, the Institution refunded $350 in 2023-2024 Federal Pell Grant program funds on behalf of student #20 (VR). In addition the Institution refunded $419 in 2024-2025 Federal Pell Grant program funds on behalf of student #2 (EL). These two students over-award was due to a schedule or grade change that took place after the start of student’s term or payment period. The Institution will implement reporting from our SIS to monitor schedule or grade changes that take place after the start of a student’s term or payment period.

View Audit 375631

Finding 1165227 (2025-001)

Material Weakness 2025

Mitchell Hamline School of Law

MN

Student Financial Aid Reporting Significant Deficiency

Recommendation: We recommend Mitchell Hamline School of Law review its reporting procedures to ensure the students' statuses are 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 respo...

Recommendation: We recommend Mitchell Hamline School of Law review its reporting procedures to ensure the students' statuses are 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: Starting in January 2026, the Registrar’s Office will be performing the monthly reporting. In preparation for this change in responsibilities, Student Financial Aid has provided training to multiple individuals in the Registrar’s Office along with detailed documented procedures. Student Financial Aid and the Registrar’s Office will coordinate responses/requests from NSLDS. Name(s) of the contact person(s) responsible for corrective action: Sheila Tolley, Executive Registrar and Nick Anderson, Director of Financial Aid Planned completion date for corrective action plan: Spring Semester 2026

View Audit 375564

Finding 1165224 (2025-003)

Material Weakness 2025

Doane University

NE

Student Financial Aid Subrecipient Monitoring

Finding 2025-003 Condition Of the sample of 25 disbursements, seven students tested did not receive proper notification of the student's right, or the parent's right to cancel any portion of the loans to be distributed. The sample was not a statistically valid sample. Corrective Action Plan To addre...

Finding 2025-003 Condition Of the sample of 25 disbursements, seven students tested did not receive proper notification of the student's right, or the parent's right to cancel any portion of the loans to be distributed. The sample was not a statistically valid sample. Corrective Action Plan To address this issue, the ERP notification process has been updated to ensure students receive clear and compliant communications regarding Direct Loan disbursements. Name(s) of Contact Person(s) Responsible for Corrective Action: Susan Collins, Director of Financial Aid Completion Date: October 17, 2025 Linda Scholting CFO 10/29/2025 Doc Management Response: Management has updated notification processes to ensure appropriate and timely notifications are sent to students.

View Audit 375536

Finding 1165223 (2025-002)

Material Weakness 2025

Doane University

NE

Student Financial Aid Subrecipient Monitoring Reporting

Finding 2025-002 Condition Of 25 students tested, the status date for one selected student was not reported in a timely manner on the campus level in the National Student Loan Data System (NSLDS). The sample was not statistically valid. Corrective Action Plan To address this issue, the Registrar’s O...

Finding 2025-002 Condition Of 25 students tested, the status date for one selected student was not reported in a timely manner on the campus level in the National Student Loan Data System (NSLDS). The sample was not statistically valid. Corrective Action Plan To address this issue, the Registrar’s Office will adjust the final spring submission date or add a fifth submission to ensure all spring updates are captured. This action resolves timing gaps caused by the non-term summer and the 60+ day interval between spring and fall semesters. Name(s) of Contact Person(s) Responsible for Corrective Action: Denise Ellis, Registrar Anticipated Completion Date: Spring submission dates will be modified or added by November 1, 2025 Linda Scholting CFO 10/29/2025 Management Response: Management has adjusted processes to ensure all student updates are correctly captured.

View Audit 375536

Finding 1165222 (2025-001)

Material Weakness 2025

Doane University

NE

Student Financial Aid Subrecipient Monitoring

Finding 2025-001 Condition During the year, there were no documented internal controls in place over the Title IV refund calculations. In the sample of 5 students who withdrew from the University, there was one student for whom the return was miscalculated. The result was too much aid being refunded...

Finding 2025-001 Condition During the year, there were no documented internal controls in place over the Title IV refund calculations. In the sample of 5 students who withdrew from the University, there was one student for whom the return was miscalculated. The result was too much aid being refunded. The sample was not statistically valid. Corrective Action Plan To address this issue, the Title IV Return of Funds Policy has been updated to strengthen accountability and compliance. All R2T4 calculations will be completed by the Financial Aid Counselor and reviewed by the Director, with signatures documenting internal controls. A checklist and quarterly reviews will ensure accuracy, and ERP integration within Ellucian Colleague, set for full implementation by October 31, 2025, will automate calculations and improve compliance monitoring. Name(s) of Contact Person(s) Responsible for Corrective Action: Susan Collins, Director of Financial Aid Anticipated Completion Date: October 31, 2025 Linda Scholting CFO 10/29/2025

View Audit 375536

Finding 1165211 (2025-001)

Material Weakness 2025

Baptist Bible College

MO

Student Financial Aid

Management agrees with the auditors’ finding and their recommendation. In August 2025, $712 of Federal Pell Grant funds were awarded to the first student in question and $260 of Federal Pell Grant funds were returned to the Department of Education for the fifth student in question. Since the remaini...

Management agrees with the auditors’ finding and their recommendation. In August 2025, $712 of Federal Pell Grant funds were awarded to the first student in question and $260 of Federal Pell Grant funds were returned to the Department of Education for the fifth student in question. Since the remaining three students were due additional Unsubsidized Federal Direct Loan funds, the College awarded additional institutional aid of $62, $93, and $93 to students two, three, and four, respectively. The Student Financial Aid Director will communicate with the Online Education Director and/or the Registrar to verify semester and enrollment dates and attend additional training webinars on R2T4 calculations hosted by the Department of Education. Anticipated Completion Date:The corrective action was completed in August 2025. Contact Person Brian Rains, Director of Financial Aid 417-268-6045

View Audit 375496

Finding 1165209 (2025-001)

Material Weakness 2025

Augustana College

IL

Student Financial Aid Reporting Significant Deficiency

Recommendation: We recommend the College evaluate its procedures and policies around reporting enrollment changes to NSLDS to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action tak...

Recommendation: We recommend the College evaluate its procedures and policies around reporting enrollment changes to NSLDS to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Augustana intends to modify the NSC/NSLDS monthly data file to ensure that campus and program enrollment dates are pulled from the appropriate data fields in the student information system. Additionally, Augustana intends to implement a step in the withdrawal process to ensure the change in status is reported accurately and timely. Name of the contact person responsible for corrective action: John Cage at johncage@augustana.edu Planned completion date for corrective action plan: January 30, 2026

View Audit 375481

Finding 1165195 (2025-001)

Material Weakness 2025

Southern Wesleyan University

SC

Reporting Student Financial Aid Eligibility

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Will need to meet with academic records and determine if Doctorate program Dissertation 1-hour course can be coded and reported as full time to NSLDS Person Responsible for Corrective Action Plan: ...

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Will need to meet with academic records and determine if Doctorate program Dissertation 1-hour course can be coded and reported as full time to NSLDS Person Responsible for Corrective Action Plan: Academic Records / Regina Bolding Harned - Registrar / Allison Sullivan – Director of Financial Aid Anticipated Date of Completion: 12/5/25

View Audit 375472

Finding 1165126 (2025-001)

Material Weakness 2025

Kansas City University

MO

Student Financial Aid Special Tests & Provisions Reporting

KCU will meet the requirements in accordance with 34 CFR Section 685.309 by reviewing the enrollment reporting submitted to NSLDS through the National Student Clearinghouse (NSC) each month and comparing to KCU’s student information system to ensure that all dates and information submitted for the m...

KCU will meet the requirements in accordance with 34 CFR Section 685.309 by reviewing the enrollment reporting submitted to NSLDS through the National Student Clearinghouse (NSC) each month and comparing to KCU’s student information system to ensure that all dates and information submitted for the month is accurate and timely. Contact Person: Cindy Miller Anticipated Completion Date: August 15, 2025

View Audit 375434

Finding 1165041 (2025-001)

Material Weakness 2025

Mid-State Technical College

WI

Student Financial Aid

It is our understanding that the issue is occurring for many instituations and appears to be due to changes in processes at the National Clearinghouse. We will monitor steps taken and updates made to maintain awareness of any resolution to the issue made at the Clearinghouse. We will also develop an...

It is our understanding that the issue is occurring for many instituations and appears to be due to changes in processes at the National Clearinghouse. We will monitor steps taken and updates made to maintain awareness of any resolution to the issue made at the Clearinghouse. We will also develop an internal process to review student status effective dates as reflected in NSLDS and make updates as needed.

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Corrective Action Plans

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