Corrective Action Plans

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Finding No. 2025-001 – Special Tests and Provisions – NSLDS Reporting – Compliance and Internal Control (Significant Deficiency) Corrective Action Plan: The School agrees with the finding. The Registrar will work with Ellucian to update reporting process to National Student Clearinghouse to include ...
Finding No. 2025-001 – Special Tests and Provisions – NSLDS Reporting – Compliance and Internal Control (Significant Deficiency) Corrective Action Plan: The School agrees with the finding. The Registrar will work with Ellucian to update reporting process to National Student Clearinghouse to include the two program lengths for same CIP code. Anticipated Completion Date: Our expected remediation date is June 15, 2026. If we are unable to remediate by June 15, 2026, we will correct enrollment reporting to reflect accurate program length by September 1, 2026. Person(s) Responsible for Corrective Action: Michelle T. Weller Registrar 212-431-2300
Finding 1201454 (2025-002)
Material Weakness 2025
Finding: The change in student status for 2 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) timely when the student withdrew or changed status during the fiscal year. The change in student status for an additional 2 of 25 students tested was not reported to th...
Finding: The change in student status for 2 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) timely when the student withdrew or changed status during the fiscal year. The change in student status for an additional 2 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) accurately when the student graduated during the fiscal year. Explanation for Finding: The Registrar's data collection was not reviewed after submission to National Student Clearinghouse (NSC) by another responsible individual to ascertain the accuracy of graduate, withdrawal and status change dates of students being reported. The College received a response from NSC of no errors, therefore the withdrawn student in question was not reported in a timely manner. Corrective Actions Taken or Planned: The Registrar will run a report on the 15th of the month to verify any students that have exited the institution from the prior two submission periods (last two months) have valid exit dates in the National Student Loan Clearinghouse. The Assistant Registrar will review the work of the Registrar and verify any discrepancies between Coe’s records and those stored in the National Student Clearinghouse for correction. The Registrar will then ensure timely and accurate submission of student records from the Clearinghouse to NSLDS after all the data has been reviewed. When there are staffing changes in the future that impact a person on the staff in the Office of the Registrar who has been responsible for the verification and reporting of valid exit dates in the National Student Loan Clearinghouse, it is the responsibility of the Registrar, unless the Registrar has left, in which case it shall be the responsibility of the Assistant Registrar, to appoint another specific staff member in the Office of the Registrar to take the actions required by the written policy for the verification and reporting of this data. Persons Responsible and Completion Date: Registrar, Assistant Registrar. The actions outlined above has been added to the Withdrawal & Exit Procedure (NSC-NSLDS) as of 10/28/2025
Corrective actions include: 1. Enhanced Monitoring Procedures o A weekly aging report of all withdrawn students will be generated by the Financial Aid Office to track the number of days elapsed since the withdrawal determination date. o The report will clearly flag any files approaching 30 days to e...
Corrective actions include: 1. Enhanced Monitoring Procedures o A weekly aging report of all withdrawn students will be generated by the Financial Aid Office to track the number of days elapsed since the withdrawal determination date. o The report will clearly flag any files approaching 30 days to ensure timely processing. 2. Documented Supervisory Review o All R2T4 calculations will be reviewed and signed off by a supervisory-level staff member prior to submission. o Evidence of review will be retained in the student’s file. 3. Holiday and Break Coverage Planning o The Financial Aid Office will establish a written coverage plan during holiday periods and institutional breaks to ensure R2T4 calculations and returns continue to be processed within required timelines. o Cross-training of at least one additional staff member has been implemented to prevent delays due to staffing constraints. 4. Periodic Internal Reconciliation o On a quarterly basis, the CFO or designee will review a summary reconciliation of all withdrawals and related R2T4 returns to verify compliance with the 45-day requirement.
Eligibility - Direct Loan Awarding Federal Direct Student Loans (84.268) Recommendation: We recommend that the University enhance its policies and procedures related to the packaging and awarding of financial aid, particularly in situations requiring manual calculations or professional judgment, to ...
Eligibility - Direct Loan Awarding Federal Direct Student Loans (84.268) Recommendation: We recommend that the University enhance its policies and procedures related to the packaging and awarding of financial aid, particularly in situations requiring manual calculations or professional judgment, to ensure student eligibility is accurately determined and awards are properly calculated. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective immediately, we've added a required review step for any aid package that is adjusted using professional judgment. This review focuses specifically on confirming that annual loan limits and subsidized eligibility are recalculated correctly after any change. Staff has also received refresher training on subsidized loan eligibility and amounts, and how to verify that the correct amount is awarded when appropriate. In addition, we will incorporate periodic spot checks of files involving manual adjustments to ensure calculations are accurate and consistent. Name(s) of the contact person(s) responsible for corrective action: Erica Riggs Planned completion date for corrective action plan: Spring 2026, ongoing.
Special Tests - Return to Title IV Funds (R2T4) Federal Direct Student Loans (84.268), Federal Pell Grant Program (84.063), Federal Supplemental Educational Opportunity Grants (84.007), and Teacher Education Assistance for College and Higher Education Grants (84.379) Recommendation: We recommend tha...
Special Tests - Return to Title IV Funds (R2T4) Federal Direct Student Loans (84.268), Federal Pell Grant Program (84.063), Federal Supplemental Educational Opportunity Grants (84.007), and Teacher Education Assistance for College and Higher Education Grants (84.379) Recommendation: We recommend that the University strengthen internal controls over the R2T 4 process by implementing standardized procedures, ensuring system calculations are accurate, and establishing consistent and documented review of R2T4 calculations prior to the return of Title IV funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective immediately, all R2T4 calculations will undergo a secondary review prior to funds being returned. The review will be documented via a shared document to ensure staff are consistently verifying withdrawal date, percentcompleted, return amounts per program, and timeliness. This document will be retained for audit purposes. We've also set internal deadlines to ensure funds are being returned within the 45-day requirement under Title IV. Calculations will be completed within 25 days of determining a withdrawal, and returns will be processed within 35 days. This will be tracked in a shared document that will also be retained for audit purposes. SOU is implementing a new Student Information System (SIS) beginning with the 2026-2027 academic year. Until we transition to the new SIS, known issues in the current SIS will be documented, and staff will manually review and override calculations where discrepancies are identified. As part of the new SIS implementation, we'll validate all R2T4 calculations to ensure system accuracy. All financial aid staff responsible for R2T4 processing will receive refresher training on calculation requirements, withdrawal date determination, and return timelines. We will also provide cross-training to additional staff to ensure continuity if there are additional staffing changes. Name(s) of the contact person(s) responsible for corrective action: Erica Riggs Planned completion date for corrective action plan: Fall 2026 and ongoing
Special Tests - Enrollment Reporting Federal Direct Student Loans and Federal Pell Grant Program - Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the thi...
Special Tests - Enrollment Reporting Federal Direct Student Loans and Federal Pell Grant Program - Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: New registrar hired 9/2025 has enhanced policies and procedures regarding enrollment reporting by initiating regular and frequent (weekly/biweekly) contact with the National Student Clearinghouse (NSC) to ensure that reporting is completed accurately and timely. Names of the contact person responsible for corrective action: Jennifer Bratz Planned completion date for corrective action plan: Correction action plan involves ongoing regular communication with NSC and regular monitoring of reports for timeliness and accuracy, no completion date.
Corrective Action Plan – Management concurs with this finding. During the student system set-up for academic year 2024-25, the appropriate screen was not properly updated with the new ISIR codes to set the tracking requirements to be posted for ISIR C Flags. Because the appropriate tracking document...
Corrective Action Plan – Management concurs with this finding. During the student system set-up for academic year 2024-25, the appropriate screen was not properly updated with the new ISIR codes to set the tracking requirements to be posted for ISIR C Flags. Because the appropriate tracking documents were not posted, the system allowed the students to pass through packaging and disbursement. The Law School Financial Aid Office will implement a structured verification process as part of the student system setup for each academic year. Every step of the setup will be documented. To ensure accuracy, one staff member will complete the setup, and a separate staff member will independently review and verify the configuration. Management believes these enhancements will be sufficient to prevent future errors. Completion date: November 2025 Persons responsible: Vonda Garcia, Director of Law School Financial Aid
Corrective Action Plan – Management concurs with this finding. The exceptions resulted from two distinct scenarios: 1) An official withdrawal processed manually outside the standardized workflow. 2) An unofficial withdrawal triggered by a grade change submitted after the final grade deadline. In Fal...
Corrective Action Plan – Management concurs with this finding. The exceptions resulted from two distinct scenarios: 1) An official withdrawal processed manually outside the standardized workflow. 2) An unofficial withdrawal triggered by a grade change submitted after the final grade deadline. In Fall 2024, an undergraduate student’s official withdrawal was completed late in the semester. The Dean requested a Torero Hub Counselor to manually remove the course, bypassing the standardized workflow. While the Counselor notified the Registrar’s Office, the Office of Financial Aid was not included in the communication chain. To address this gap, the Office of Financial Aid will implement a biweekly report to monitor and verify any changes to student withdrawal statuses that fall outside the automated workflow. Management believes this enhancement will effectively prevent similar errors in the future. The second exception involved a Professional and Continuing Education (PCE) student. After the final grade submission deadline, the instructor updated the student’s grade to an ‘F’, which retroactively classified the student as an unofficial withdrawal. This change occurred after the Office of Financial Aid had already run the final Fall 2024 unofficial withdrawal report. PCE has been notified that grade changes are not permitted after the final grade deadline. Additionally, the Office of Financial Aid will now run the unofficial withdrawal report biweekly beyond the final grade due date to identify and verify any late changes to student withdrawal statuses. Management believes these measures will mitigate the risk of future occurrences. Completion date: September 2025 Persons responsible: Kellie Nehring, Director of Financial Aid and Diana Hannasch-Haag, Director of Retention – Online Degree Programs
CORRECTIVE ACTION The Registrar and the Assistant Director of Financial Aid will be included in the receipt of the graduation file. The graduation file will be uploaded in the National Student Clearinghouse (NSC) and the Registrar will alert the Financial Aid office when submitted. The Registrar wil...
CORRECTIVE ACTION The Registrar and the Assistant Director of Financial Aid will be included in the receipt of the graduation file. The graduation file will be uploaded in the National Student Clearinghouse (NSC) and the Registrar will alert the Financial Aid office when submitted. The Registrar will confirm in NSC the file was uploaded with no errors for campus level and program level reporting. The Office of Financial Aid will add to its current procedure to request additional reports from NSLDS (campus level and program level), 3 weeks after the file has been uploaded to NSC; to show graduates and withdrawal information reported at the program and campus levels. The Dean of Enrollment and Financial Aid will also set a calendar alert for comparing the degree verify file against the NSLDS reports for discrepancies. Should discrepancies arise, the Assistant Director of Financial Aid and the Registrar will work together to address and correct the issues before 60 days post-graduation. Anticipated Date of Completion: In place for the 2025-2026 academic year.
Student Financial Assistance Cluster – 84.063 and 84.268 Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disag...
Student Financial Assistance Cluster – 84.063 and 84.268 Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: The College utilizes a third-party, National Student Clearinghouse (NSC) to report to the National Student Loan Data System (NSLDS). Clarification was obtained from NSC regarding the process between NSC and NSLDS to prevent future occurrences. The NSC report will be submitted at the earliest possible date to provide additional time to review and verify that accurate data was transferred from NSC to NSLDS. Name of the contact person responsible for corrective action: Jonathan Jett, Director of Financial Aid Planned completion date for corrective action plan: June 30, 2026
Student Financial Assistance Cluster– Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Recommendation: We recommend the College implement procedures to review accuracy of information used to calculate R2T4s. Explanation of disagreement with audit finding: There is no disagreement with t...
Student Financial Assistance Cluster– Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Recommendation: We recommend the College implement procedures to review accuracy of information used to calculate R2T4s. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: Financial aid staff have added to our Return to Title IV procedures that we complete the calculation in Colleague and the U.S. Department of Education Common Origination & Disbursement to make sure all amounts are correct. The Financial Aid Manager completes the calculation, and the Director then reviews and sends any questions/concerns back to the Financial Aid Manager. The Director will approve once any concerns are addressed. Name of the contact person responsible for corrective action: Jonathan Jett, Director of Financial Aid Planned completion date for corrective action plan: June 30, 2026
Student Financial Assistance Cluster– Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Recommendation: We recommend the college update procedures around disbursements of credit balances and implement controls to ensure credit balances are being returned timely. Explanation of disagreeme...
Student Financial Assistance Cluster– Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Recommendation: We recommend the college update procedures around disbursements of credit balances and implement controls to ensure credit balances are being returned timely. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: Prior to FY23, students signed a form acknowledging and authorizing the College to have credit balances held on their account in the event there would be classes added and to purchase books. During FY2023, this procedure was discontinued for an unrelated reason and an unintended consequence was not meeting the 14-day requirement. A new procedure was developed and implemented in January, 2025. The 10 credit balance refunds from the population of 60 were from the period of July 1, 2024, through December 31, 2025. The prior year audit was released on November 15, 2025, at which point all credit balances had already been refunded under the prior procedures. There wasn’t an opportunity to correct the situation until the spring semester in 2025. Name of the contact person responsible for corrective action: Jonathan Jett, Director of Financial Aid Planned completion date for corrective action plan: Completed
Corrective Action Plan 2025-005: Management concurs with the finding. The University is revising its procedures to ensure all post-withdrawal disbursement offers are properly issued and documented and will implement additional controls and staff training to ensure future compliance with federal R2T4...
Corrective Action Plan 2025-005: Management concurs with the finding. The University is revising its procedures to ensure all post-withdrawal disbursement offers are properly issued and documented and will implement additional controls and staff training to ensure future compliance with federal R2T4 requirements. Completion Date: February 2026 Contact Person: Joanne Rozborski, Assistant Vice President, Student Financial Services
Corrective Action Plan 2025-004: Management concurs with the finding. The University is revising its procedures to ensure timely processing of all required R2T4 returns and is implementing additional internal controls and monitoring steps to ensure compliance with the 45-day return requirement. Comp...
Corrective Action Plan 2025-004: Management concurs with the finding. The University is revising its procedures to ensure timely processing of all required R2T4 returns and is implementing additional internal controls and monitoring steps to ensure compliance with the 45-day return requirement. Completion Date: February 2026 Contact Person: Joanne Rozborski, Assistant Vice President, Student Financial Services
Corrective Action Plan 2025-003: Management concurs with the finding. The University is updating its written R2T4 procedures to ensure the appropriate scheduled end date is consistently used for students enrolled in modular programs. System enhancements and new workflow controls will be implemented ...
Corrective Action Plan 2025-003: Management concurs with the finding. The University is updating its written R2T4 procedures to ensure the appropriate scheduled end date is consistently used for students enrolled in modular programs. System enhancements and new workflow controls will be implemented to require documentation of all modules a student was scheduled to attend. The University will work to recalculate returns for students who withdrew from modules as recommended. Anticipated Completion Date: March 2026 Contact Person: Joanne Rozborski, Assistant Vice President, Student Financial Services
Corrective Action Plan 2025-002: Management concurs with the finding. The University has implemented controls to ensure that academic grade level progression and COA/OFA adjustments trigger a mandatory review of eligibility through the use of new reports and workflows. Completion Date: February 2026...
Corrective Action Plan 2025-002: Management concurs with the finding. The University has implemented controls to ensure that academic grade level progression and COA/OFA adjustments trigger a mandatory review of eligibility through the use of new reports and workflows. Completion Date: February 2026 Contact Person: Joanne Rozborski, Assistant Vice President, Student Financial Services
Management is responsible for ensuring accurate and timely reporting of enrollment data to the appropriate governmental authorities. Personnel Responsible for Corrective Action: Josh Dining, Controller Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2026. Correcti...
Management is responsible for ensuring accurate and timely reporting of enrollment data to the appropriate governmental authorities. Personnel Responsible for Corrective Action: Josh Dining, Controller Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2026. Corrective Action Plan – Management has provided training and is aware of the federal regulations surrounding enrollment reporting. The financial aid department will make regular updates to NSLDS on a monthly basis to ensure student information is reported accurately and timely.
Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: As a result of the 24-25 annual audit and the Department of Education’s Program Review that is just being wrapped up now, I’ve worked with our IT department and Brightspace department on updating our data retrieval. The update to t...
Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: As a result of the 24-25 annual audit and the Department of Education’s Program Review that is just being wrapped up now, I’ve worked with our IT department and Brightspace department on updating our data retrieval. The update to this process started in November of 2024 and concluded in May of 2025. We now have updated processes and reports in place that allow for quicker notification of withdrawals, non-attendance, and failed courses. The report is now run at least once a month to capture any changes in enrollment for students who fall into these categories. This information is also being included in the Department of Education’s Program Review response that will be submitted to them by the end of March 2026. Person Responsible for Corrective Action Plan: Andréa L. Ruth- Director of Financial Aid Anticipated Date of Completion: March 31, 2026
The University of Massachusetts acknowledges the enrollment status of certain students was not accurately or timely transmitted to the National Student Loan Data System (NSLDS). The University will implement additional controls and procedures to ensure data is transmitted to NSLDS correctly and time...
The University of Massachusetts acknowledges the enrollment status of certain students was not accurately or timely transmitted to the National Student Loan Data System (NSLDS). The University will implement additional controls and procedures to ensure data is transmitted to NSLDS correctly and timely, including increased reviews of data submitted to NSDLS, and a reconciliation of student status with NSLDS. The corrective action plan will be implemented by May 31, 2026. For further details regarding the corrective action plan, contact the Assistant Vice President and University Controller, Patrick Hitchcock, at phitchcock@umassp.edu
Identifying Number: 2025-003: U.S. Department of Education: Federal Direct Student Loans – 84.268 Finding: During testing over enrollment reporting, one instance was identified where a student’s program begin date was incorrectly reported to NDSLDS. Corrective Action Taken or Planned: There were sev...
Identifying Number: 2025-003: U.S. Department of Education: Federal Direct Student Loans – 84.268 Finding: During testing over enrollment reporting, one instance was identified where a student’s program begin date was incorrectly reported to NDSLDS. Corrective Action Taken or Planned: There were several instances of dates submitted through the National Student Clearinghouse to NSLDS where dates were not aligning to submissions. In all but one case, those dates were confirmed to be matching the NSC submission and were not found to be erroneous. The one date is suspected to be due to a program change and those students with changes will be monitored by the Registrar and the Financial Aid Office. Contact person: Micah Hansen, Director of Financial Aid Status of finding – The above corrective actions will be implemented beginning January 1, 2026.
Identifying Number: 2025-002: U.S. Department of Education: Federal Direct Student Loans – 84.268; Federal Pell Grant Program – 84.007 Finding: During testing over credit balances, it was noted that one student did not receive the refund on a timely basis. Corrective Action Taken or Planned: All sch...
Identifying Number: 2025-002: U.S. Department of Education: Federal Direct Student Loans – 84.268; Federal Pell Grant Program – 84.007 Finding: During testing over credit balances, it was noted that one student did not receive the refund on a timely basis. Corrective Action Taken or Planned: All scheduled disbursements will be reviewed to ensure they are provided on a timely basis and are applied correctly to prior award years. Business Office procedures and processing will be reviewed to ensure that credit balances are processed within the regulatory timeframe. New staff have been trained to monitor dates for compliance and have implemented checks with the Financial Aid Office. Contact person: Micah Hansen, Director of Financial Aid and Christine Goldsmith, Vice President - Finance Status of finding – The above corrective actions will be implemented beginning January 1, 2026.
Finding Number: 2025-009 Condition: The College did not have established written cash management procedures. Planned Corrective Action: The College agrees with the finding. Although the College has processes in place to ensure appropriateness of draws and review of expenditures both individually and...
Finding Number: 2025-009 Condition: The College did not have established written cash management procedures. Planned Corrective Action: The College agrees with the finding. Although the College has processes in place to ensure appropriateness of draws and review of expenditures both individually and in aggregate, the process and procedures are not documented. The College will document cash management procedures and related internal controls. Contact person responsible for corrective action: Kayla Flanders Anticipated Completion Date: 6/30/2026
Finding Number: 2025-008 Condition: The College did not accurately report certain changes to NSLDS. Planned Corrective Action: The College agrees with the finding. The College acknowledges the error in reporting. The College will evaluate its internal control processes around data transmission throu...
Finding Number: 2025-008 Condition: The College did not accurately report certain changes to NSLDS. Planned Corrective Action: The College agrees with the finding. The College acknowledges the error in reporting. The College will evaluate its internal control processes around data transmission through a third party to ensure that information is accurately reported to avoid future errors and make enhancements and improvements as necessary. Contact person responsible for corrective action: Kayla Flanders Anticipated Completion Date: 6/30/2026
Finding Number: 2025-007 Condition: The College did not have appropriate internal controls in place related to the version updates, patches, and modifications in the student and general ledger systems. Planned Corrective Action: The College agrees with the finding. The CFO and Controller will work w...
Finding Number: 2025-007 Condition: The College did not have appropriate internal controls in place related to the version updates, patches, and modifications in the student and general ledger systems. Planned Corrective Action: The College agrees with the finding. The CFO and Controller will work with the CIO to ensure that appropriate internal controls, including segregation of duties, around system upgrades, patches and modifications are completed. The internal control processes will cover the following key areas: • Planning and Authorization of the upgrade, patch or change • Implementation and Testing of the upgrade, patch or change, including user acceptance testing • Change Management and Documentation of the change, including logs or appropriate audit trails • Post Implementation Monitoring and Review Contact person responsible for corrective action: Kayla Flanders Anticipated Completion Date: 6/30/2026
Finding Number: 2025-006 Condition: The College did not notify students receiving loan or TEACH disbursements within 30 days of crediting the students' account. Planned Corrective Action: The College agrees with the finding. The College will review the internal processes and procedures around studen...
Finding Number: 2025-006 Condition: The College did not notify students receiving loan or TEACH disbursements within 30 days of crediting the students' account. Planned Corrective Action: The College agrees with the finding. The College will review the internal processes and procedures around student notification to ensure that all required notifications are completed within the designated timeframe. The CFO and Controller will work with the Financial Aid office to ensure the process is documented and complied with. Contact person responsible for corrective action: Kayla Flanders Anticipated Completion Date: 6/30/2026
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