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Corrective Action Plans

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Finding 519 (2023-001)
Significant Deficiency 2023
Faulkner University
AL
Student Financial Aid Special Tests & Provisions Reporting
Corrective Action Plan for Finding 2023-001 - The University experienced turnover in the Institutional Research position that attributed to the reporting errors. The University will provide additional training and monitoring to ensure that information reported to the National Student Loan Data Syst...
Corrective Action Plan for Finding 2023-001 - The University experienced turnover in the Institutional Research position that attributed to the reporting errors. The University will provide additional training and monitoring to ensure that information reported to the National Student Loan Data System (NSLDS) is timely and accurate. The University also has a team represented by personnel from the Financial Aid office and Registrar's office that are evaulating our third-party agent assisting with enrollment verification reporting to the NSLDS, and the University will make a change in that relationship if warranted. The corrective action is currently in process and is being coordinated by Michelle Otwell, Assistant Professor and University Registrar; Breanna Yarbrough, Assistant Professor and Director of the Center for Assessment, Research, Effectiveness & Enhancement (CAREE); Linda Pynes, Director of Financial Aid. The corrective training will be completed immediately and monitoring will be an ongoing activity. The decision on whether to make a change in the agent assisting with transmitting data to the NSLDS will be made before May 31, 2024.
View Audit 1049
Brescia University Inc.
KY
Special Tests & Provisions Student Financial Aid
The Director of Financial Aid reviewed all students who had withdrawn and determined that only two were impacted. These two students' refund calculations were reviewed and corrected, and appropriate funds were returned. The dates used in the R2T 4 calculation for the upcoming year have been reviewed...
The Director of Financial Aid reviewed all students who had withdrawn and determined that only two were impacted. These two students' refund calculations were reviewed and corrected, and appropriate funds were returned. The dates used in the R2T 4 calculation for the upcoming year have been reviewed by the Director of Financial Aid to verify the proper number of days will be used in the Title IV Refund calculations. The Assistant Registrar will review the academic calendar each semester to be used in the R2T4 calculations. The University implemented these procedures for the Fall 2023 semester.
View Audit 1009
Finding 458 (2023-001)
Significant Deficiency 2023
Brescia University Inc.
KY
Special Tests & Provisions Student Financial Aid Reporting
To prevent future errors and oversight in the preparation and review process, hard copies of the documents used to prepare the FI SAP will be cross-checked and verified by the Student Financial Aid Director. The documentation of the review then will be re-verified by the Vice President of Business &...
To prevent future errors and oversight in the preparation and review process, hard copies of the documents used to prepare the FI SAP will be cross-checked and verified by the Student Financial Aid Director. The documentation of the review then will be re-verified by the Vice President of Business & Finance. The University implemented these procedures for the FI SAP due October 1, 2023.
View Audit 1009
Howard Payne University
TX
Reporting Student Financial Aid Eligibility
Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A review is being completed by the Registrar’s Office to determine if something is in the student record that may prevent a student from being reported correctly. If a common factor can be determined, then ...
Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A review is being completed by the Registrar’s Office to determine if something is in the student record that may prevent a student from being reported correctly. If a common factor can be determined, then it will be corrected. Until then, Enrollment reporting to NSC will be reviewed twice. Follow up will be done regarding last date of attendance reporting for those students who do fail to complete the semester. Person Responsible for Corrective Action Plan: Karen LaQuey, Director, Student Financial Aid Director; Wendy McNeeley, previous Registrar; Kristina Penland, Registrar Anticipated Date of Completion: 12/12/2023
View Audit 959
Finding 375 (2023-002)
Significant Deficiency 2023
Amberton University
TX
Student Financial Aid Reporting
Amberton University will strengthen the internal controls related to NSLDS reporting and provide additional training to ensure data is reported accurately to ensure proper compliance with the established guidelines. The University is also beginning to work with the National Student Clearinghouse in ...
Amberton University will strengthen the internal controls related to NSLDS reporting and provide additional training to ensure data is reported accurately to ensure proper compliance with the established guidelines. The University is also beginning to work with the National Student Clearinghouse in the reporting of enrollment information.
View Audit 793
Finding 374 (2023-001)
Significant Deficiency 2023
Amberton University
TX
Student Financial Aid Reporting
Amberton University will strengthen the internal controls related to notifying students of the requirement to complete Exit Counseling and will provide additional training to ensure proper compliance with the established guidelines. Additional steps have been implemented to provide notification of e...
Amberton University will strengthen the internal controls related to notifying students of the requirement to complete Exit Counseling and will provide additional training to ensure proper compliance with the established guidelines. Additional steps have been implemented to provide notification of exit counseling to students.
View Audit 793
Southern Virginia University
VA
Questioned Costs Student Financial Aid Reporting
Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: An incorrect date was used to process one student’s Return of Title IV (R2T4) calculation. Training has been provided to financial aid staff in properly performing the R2T4 calculations and a ...
Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: An incorrect date was used to process one student’s Return of Title IV (R2T4) calculation. Training has been provided to financial aid staff in properly performing the R2T4 calculations and a report is being run several times a month to identify possible data entry errors in R2T4 calculations. Anticipated Completion Date: Completed
View Audit 719 Questioned Costs: $1
Finding 344 (2023-002)
Significant Deficiency 2023
Southern Virginia University
VA
Student Financial Aid Special Tests & Provisions Reporting
Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: The majority of the certification delays were one day late. Corrective action has been taken. The financial aid office is working jointly with the registrar’s office to report enrollment infor...
Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: The majority of the certification delays were one day late. Corrective action has been taken. The financial aid office is working jointly with the registrar’s office to report enrollment information via the National Student Clearinghouse (NSC) which will facilitate more timely reporting of future enrollment status changes to NSLDS and reporting of all significant data elements to NSLDS. Reporting to NSC by the University Registrar’s Office has begun. Anticipated Completion Date: Completed
View Audit 719
Southern Virginia University
VA
Student Financial Aid Subrecipient Monitoring Cash Management
Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: This finding affected a mere 2 of 40 records tested. Corrective action has been taken. The financial aid office has set up daily disbursement record submissions through its financial aid proce...
Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: This finding affected a mere 2 of 40 records tested. Corrective action has been taken. The financial aid office has set up daily disbursement record submissions through its financial aid processing system, Jenzabar Financial Aid, which will simplify the process and prevent reporting delays. Anticipated Completion Date: Completed
View Audit 719
Chowan University
NC
Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring
Name of Responsible Individual: Ruth Casper & Stephanie Furlough Corrective Action: The University Financial Aid Office has restructured the disbursement process as noted below: • Staff members will be retrained on the importance of timely reporting and record compliance. • A disbursement and docum...
Name of Responsible Individual: Ruth Casper & Stephanie Furlough Corrective Action: The University Financial Aid Office has restructured the disbursement process as noted below: • Staff members will be retrained on the importance of timely reporting and record compliance. • A disbursement and documentation process will be created to track, manage and reconcile the disbursement requests sent to COD. This process will aidin recognizing approved disbursements, rejected requests, and posting of disbursements. • The disbursement and reconciliation log will be reviewed by the Asst. Vice President for Student Financial Services as well as the Asst Vice President for Analytics & Audit. Anticipated Completion Date: The disbursement procedures will be monitored on an ongoing basis.
View Audit 409
Finding 209 (2023-001)
Significant Deficiency 2023
University of Health Sciences and Pharmacy in St Louis
MO
Student Financial Aid Subrecipient Monitoring Reporting
The enrollment reporting issue specifically relates to the integrated BS/PharmD degree program. The University's primary operating system, Jenzabar, reports concurrent enrollment status for P1 students and students who have graduated from the bachelor's degree component of the program. Since the N...
The enrollment reporting issue specifically relates to the integrated BS/PharmD degree program. The University's primary operating system, Jenzabar, reports concurrent enrollment status for P1 students and students who have graduated from the bachelor's degree component of the program. Since the National Student Clearinghouse's (NSC's) system automatically overrides the graduation data in the University's Jenzabar report without notifying the University, a two-step corrective action plan has been initiated. The modified reporting process to improve internal controls consists of the following steps: 1. Upload the initial Jenzabar enrollment reporting into the NSC system which will show full-time enrollment for both the bachelor's degree and the PharmD program; 2. File a second report reflecting the date of completion of the bachelor's degree for all students in the integrated program to remedy the NSC system override of graduation data in the initial Jenzabar report; and 3. Conduct a manual verification of graduation data in the National Student Loan Data System to ensure complete, accurate and timely reporting of graduation information from NSC. The modified reporting process is expected to be fully implemented at the conclusion of the 2023-2024 academic year in conjunction with completion of commencement, which is scheduled to occur in May 2024.
View Audit 398
Finding 137 (2023-003)
Significant Deficiency 2023
Virginia Union University
VA
Student Financial Aid Matching / Level of Effort / Earmarking
Criteria: Regulations require the Institution ensure exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate borrower shortly before the student borrower ceases at least half-time study. Exit counseling must be conducted within 30 days after th...
Criteria: Regulations require the Institution ensure exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate borrower shortly before the student borrower ceases at least half-time study. Exit counseling must be conducted within 30 days after the school learns the student borrower has withdrawn from school or failed to complete the exit counseling [34 CFR 685.304(b), (1) & 34 CFR 674.42(b)]. The University concurs with this finding and will adhere to the corrective action plan. Corrective Action: The audit for FY22 was not finalized until June 27, 2023. The plan date for correction for this finding was December 31, 2023. Therefore, the plan was not realized due to the timing of completion of the FY22 audit. Now that the FY23 audit is completed, the Registrar will email exit counseling materials as an attachment to the email or send a email containing URL or hyperlink which will take the student directly to the Exit Counseling page on StudentAid.gov. Responsbile Person(s): Doreen Dixon, Registrar ddixon@vuu.edu 804 257-5845. Robert Merino, Executive Director jrmerino@vuu.edu 281 795-6190. Planned Date of Completion of Corrective Action: December 31, 2023.
View Audit 218
Finding 133 (2023-002)
Significant Deficiency 2023
Virginia Union University
VA
Student Financial Aid Matching / Level of Effort / Earmarking Reporting
Criteria: Under the Pell grant and ED loan programs, Institutions are responsbile for timely enrollment reporting to the NSLDS whether they report directly or via a third-party servicer such as the National Student Clearinghouse (NSC). Enrollment reporting in a timely and accurate manner is critical...
Criteria: Under the Pell grant and ED loan programs, Institutions are responsbile for timely enrollment reporting to the NSLDS whether they report directly or via a third-party servicer such as the National Student Clearinghouse (NSC). Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 60 days whenever enrollment status changes for students unless a roster is submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leave-of-absence. The University concurs with this finding and will adhere to the corrective action plan. Corrective Action: The audit for FY22 was not finalized until June 27, 2023. The plan date for correction for this finding was December 31, 2023. Therefore, the plan was not realized due to the timing of completion of the FY22 audit. Now that the FY23 audit is completed, the Registrar and Information Technology will ensure monthly reporting to the National Clearinghouse. In addition, the Registrar will determine the root cause is corrected and enrollment is reported correctly. These procedures will become part of the Registrar's Standard Operating Procedures. Responsbile Person(s): Doreen Dixon, Registrar ddixon@vuu.edu 804 257-5845. Kofi Jack, Chief Information Officer kjack@vuu.edu 804 257-5709. Planned Date of Completion of Corrective Action: December 31, 2023.
View Audit 218
Finding 129 (2023-001)
Significant Deficiency 2023
Virginia Union University
VA
Student Financial Aid Cash Management Matching / Level of Effort / Earmarking
Criteria: Institutions are required to report all Direct Loan (DL) disbursements and submit required records to the Department of Education's Common Origination and Disbursement (COD) which is a web-based system for processing, storing and reconciling DL financial aid data. Each month, the COD provi...
Criteria: Institutions are required to report all Direct Loan (DL) disbursements and submit required records to the Department of Education's Common Origination and Disbursement (COD) which is a web-based system for processing, storing and reconciling DL financial aid data. Each month, the COD provides Institutions with a School Account Statement (SAS) date file which consists of a Cash Summary, Cash Detail and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the Insitution's financial records ("DL Reconciliations"). While the University has made significant improvements in this reconciliation process and that of the other related federal award programs, there are still unreconciled differences in all three major federal pass-through program's reonciliations as noted in the financial statement audit. However, for FY23, these differences netted to an immaterial difference overall and were no adjusted / passed during the financial statement audit. However, differences still remain, and the reconciliation process still needs to be improved upon. The University concurs with the audit finding and will adhere to the corrective action plan. Corrective action: The Student Financial Aid activity was reconciled among the Registrar, Financial Aid, and Business Offices as of June 30, 2023, at detailed (student) level. Monthly reconciliations will be maintained effective July 2023. Responsible Person(s): Robert Merino, Executive Director of Financial Aid jrmerino@vuu.edu 218 795-6190. Planned Date of Completion of Corrective Action: December 31, 2023.
View Audit 218
Finding 127 (2023-002)
Significant Deficiency 2023
St. Ambrose University
IA
Student Financial Aid Reporting
The University did not timely disburse a Pell grant to an eligible student within the payment period. Corrective Actions Taken or Planned: Run the pending Pell Grant report weekly and investigate any returning corrections that were delayed by CPS such as this case. Anticipated Completion Date: Augu...
The University did not timely disburse a Pell grant to an eligible student within the payment period. Corrective Actions Taken or Planned: Run the pending Pell Grant report weekly and investigate any returning corrections that were delayed by CPS such as this case. Anticipated Completion Date: August 1, 2023 Contact Person: Julie Haack
View Audit 208
Finding 126 (2023-001)
Significant Deficiency 2023
St. Ambrose University
IA
Student Financial Aid Reporting Matching / Level of Effort / Earmarking
The University did not accurately or timely report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: Based on these circumstances of a reported status being overwritten by a monthly update, we will do a random audit of all reported withdrawn s...
The University did not accurately or timely report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: Based on these circumstances of a reported status being overwritten by a monthly update, we will do a random audit of all reported withdrawn students to make sure the correct status has flowed through to NSLDS from NSLC Anticipated Completion Date: December 1, 2023 Contact Person: Julie Haack
View Audit 208
Finding 1208190 (2022-005)
Material Weakness 2022
Christian Theological Seminary, Inc.
IN
Student Financial Aid Subrecipient Monitoring Matching / Level of Effort / Earmarking
The Seminary has developed, with the assistance of our outsourced vCIO and vChief Security Officer, a comprehensive security plan which meets the standards required by the Gramm- Leach-Bliley Act.
The Seminary has developed, with the assistance of our outsourced vCIO and vChief Security Officer, a comprehensive security plan which meets the standards required by the Gramm- Leach-Bliley Act.
View Audit 399050
Finding 1208189 (2022-004)
Material Weakness 2022
Christian Theological Seminary, Inc.
IN
Student Financial Aid Matching / Level of Effort / Earmarking
The Financial Aid Director, in conjunction with the Registrar, will review all student withdrawals to ensure that R2T 4 calculations are completed on time. At the midpoint of the semester and other review will be done to ensure that all calculations were completed and on time.
The Financial Aid Director, in conjunction with the Registrar, will review all student withdrawals to ensure that R2T 4 calculations are completed on time. At the midpoint of the semester and other review will be done to ensure that all calculations were completed and on time.
View Audit 399050
Finding 1208188 (2022-003)
Material Weakness 2022
Christian Theological Seminary, Inc.
IN
Student Financial Aid
The Registrar will review all leaves of absence to ensure that all paperwork is completed. This occurred during a period of transition within the Registrars Office and collection of paperwork is checked and verified more thoroughly now.
The Registrar will review all leaves of absence to ensure that all paperwork is completed. This occurred during a period of transition within the Registrars Office and collection of paperwork is checked and verified more thoroughly now.
View Audit 399050
Finding 528934 (2022-009)
Material Weakness 2022
Iliff School of Theology
CO
Student Financial Aid Matching / Level of Effort / Earmarking Material Weakness
Condition: The Institution does not have evidence that exit counseling was provided to students who withdrew or graduated as required by 34 CFR 682.604. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its stude...
Condition: The Institution does not have evidence that exit counseling was provided to students who withdrew or graduated as required by 34 CFR 682.604. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school has also ensured that this third-party processor is properly coordinated with the registrar’s office to meet federal requirements for exit counseling when status changes are processed. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024
View Audit 346905
Finding 528932 (2022-007)
Material Weakness 2022
Iliff School of Theology
CO
Student Financial Aid Material Weakness Matching / Level of Effort / Earmarking
Condition: The Institution does not have a documented Direct Loan quality assurance program. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school will coordinate with this third-...
Condition: The Institution does not have a documented Direct Loan quality assurance program. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school will coordinate with this third-party processor to ensure that there is a documented quality assurance program that is regularly exercised for compliance purposes. All documentation will be maintained. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024
View Audit 346905
Finding 528931 (2022-006)
Material Weakness 2022
Iliff School of Theology
CO
Questioned Costs Student Financial Aid Material Weakness
Condition: Our audit procedures identified an instance where the Institution could not locate evidence that the required R2T4 calculation under federal regulation was completed. The total aid disbursed to this student was $5,125. Planned Corrective Action: The Iliff School of Theology has contracte...
Condition: Our audit procedures identified an instance where the Institution could not locate evidence that the required R2T4 calculation under federal regulation was completed. The total aid disbursed to this student was $5,125. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. This third-party processor is adequately skilled to complete Return of Title IV calculations and includes an established review process for quality control. All documentation will be maintained. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024
View Audit 346905 Questioned Costs: $1
Finding 528930 (2022-005)
Material Weakness 2022
Iliff School of Theology
CO
Student Financial Aid Material Weakness Matching / Level of Effort / Earmarking
Condition: The Institution does not reconcile institutional records with Direct Loan funds received from the Secretary of the U.S. Department of Education and the Direct Loan disbursement records submitted to and accepted by the Secretary of the U.S. Department of Education. Planned Corrective Acti...
Condition: The Institution does not reconcile institutional records with Direct Loan funds received from the Secretary of the U.S. Department of Education and the Direct Loan disbursement records submitted to and accepted by the Secretary of the U.S. Department of Education. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs who will ensure that direct loan reconciliations are conducted on a monthly basis in coordination with the business office. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024
View Audit 346905
Finding 528927 (2022-002)
Material Weakness 2022
Iliff School of Theology
CO
Student Financial Aid Reporting Material Weakness
Condition: Our audit procedures identified instances of inaccurate or untimely reporting of enrollment information to NSLDS. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school ...
Condition: Our audit procedures identified instances of inaccurate or untimely reporting of enrollment information to NSLDS. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school has also ensured that this third-party processor is properly coordinated with the registrar’s office to meet federal requirements for NSLDS enrollment reporting. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024
View Audit 346905
Finding 528926 (2022-010)
Significant Deficiency 2022
Iliff School of Theology
CO
Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking
Condition: Our audit procedures identified instances of MPNs not being properly maintained. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school has also ensured that this third-...
Condition: Our audit procedures identified instances of MPNs not being properly maintained. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school has also ensured that this third-party processor is properly reviewing MPNs to meet federal requirements. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024
View Audit 346905
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