Corrective Action Plans

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Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in r...
Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Seminary will continue to review and update our current WISP to comply with all requirements and updated standards. Name(s) of the contact person(s) responsible for corrective action: Raymond Ingram Planned completion date for corrective action plan: June 2026
Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend the Seminary evaluate its procedures and policies around reporting Unsubsidized loan disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding:...
Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend the Seminary evaluate its procedures and policies around reporting Unsubsidized loan disbursements to COD 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 finding: The Business Office will post the awarded funds to the accounts in SONIS on the date designated on the disbursement roster. Name(s) of the contact person(s) responsible for corrective action: Razieh Adinehzadeh Planned completion date for corrective action plan: March 2026
Finding Number: 2025-020 Finding: The University of Washington did not have adequate internal controls to ensure it notified the Department of Education of changes in student enrollment information accurately and in a timely manner for the Federal Pell Grant and Direct Student Loan programs. Program...
Finding Number: 2025-020 Finding: The University of Washington did not have adequate internal controls to ensure it notified the Department of Education of changes in student enrollment information accurately and in a timely manner for the Federal Pell Grant and Direct Student Loan programs. Program: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Compliance Requirement: Special Tests and Provisions – NSLDS Reporting Questioned Costs: $0 Status: Corrective action in progress Corrective Action: To address the audit recommendations, the University will take the following actions to strengthen monitoring and audit of the National Student Loan Data System (NSLDS) and university records to ensure enrollment reporting is timely, accurate, and complete. • The Office of the University Registrar (OUR) will reinforce and refine its quarterly audit and reconciliation activities to compare NSLDS enrollment information with institutional records subsequent to National Student Clearinghouse (NSC) submissions. • OUR will document and report discrepancies and follow a designated escalation path for resolution. A documented supervisory review will be established to strengthen internal controls. • OUR will document all current and new enrollment reporting processes and ensure sufficient written procedures are provided to primary and backup staff to perform the functions effectively. • OUR will review NSLDS records and enrollment data for the audit period and ensure accurate reporting of enrollment status. • The University will establish a policy and procedure for the retention of source documentation provided to NSC. Prior Findings: None Completion Date: Estimated August 2026 Agency Contact: Erick Winger Controller (206) 543-5322 erickw@uw.edu
Finding Number: 2025-037 Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with requirements to ensure Foster Care Maintenance payment rates were properly calculated. Program: 93.658 – Foster Care Title IV-E Compliance Requiremen...
Finding Number: 2025-037 Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with requirements to ensure Foster Care Maintenance payment rates were properly calculated. Program: 93.658 – Foster Care Title IV-E Compliance Requirement: Special Tests and Provisions – Payment Rate Setting and Application Questioned Costs: $0 Status: Corrective action in progress Corrective Action: The Department concurs that policies and procedures related to rate setting for Foster Care maintenance payments are not currently established and is committed to strengthening internal controls and complying with federal requirements. In February 2025, the Department met with the State Auditor’s Office to gather an understanding of concerns and discuss how reasonable and allowable rates could be documented to ensure federal compliance. In July 2025, the Department began drafting the written policies and procedures for setting payment rates to ensure maintenance payment rates only include allowable costs. The Department will continue to follow internal processes to complete the payment and rate setting policies and procedures. Prior Findings: The conditions noted in this finding were previously reported in finding 2024-071. Completion Date: Estimated July 2026 Agency Contact: Stefanie Niemela Audit Liaison (360) 725-4402 stefanie.niemela@dcyf.wa.gov
The University acknowledges the audit finding regarding the reporting of undergraduate tuition and fees on the Fiscal Operations Report and Application to Participate (FISAP). We appreciate the auditors' review and agree that the amounts reported did not align with the institution's underlying recor...
The University acknowledges the audit finding regarding the reporting of undergraduate tuition and fees on the Fiscal Operations Report and Application to Participate (FISAP). We appreciate the auditors' review and agree that the amounts reported did not align with the institution's underlying records due to the use of net tuition and fee data that included both undergraduate and graduate/professional activity. To address the findings, Lincoln has implemented the following corrective measures: - Procedures have been updated to ensure that only gross undergraduate tuition and fee data-consistent with FISAP reporting requirements will be used in future submissions. - Financial Aid and Finance staff will jointly review the FSAP instructions and clarify the data elements required for accurate reporting. - A cross-departmental reconciliation step between Financial Aid and Finance prior to FISAP submission. - Documentation of data sources and validation steps to ensure consistency with underlying financial records. The corrective measures above are designed to ensure amounts reported for tuition and fees on the FISAP align with the institution's underlying records.
The Office of Student Financial Services acknowledges the finding related to the Return of Title IV Funds. We recognize the importance of ensuring accurate calculations and timely return of unearned Title IV funds as part of our federal compliance obligations. The Office of Student Financial Service...
The Office of Student Financial Services acknowledges the finding related to the Return of Title IV Funds. We recognize the importance of ensuring accurate calculations and timely return of unearned Title IV funds as part of our federal compliance obligations. The Office of Student Financial Services will strengthen procedures for Return of Title IV (R2T4) calculations. All withdrawals will be reviewed using the R2T4 calculation worksheet, and calculations will be verified by a second staff member prior to posting. A tracking log will be maintained to ensure funds are returned within required timeframes. Written procedures will be updated to include required timelines and review steps. Staff training will be conducted to ensure consistent application of federal regulations. The Director of Financial Aid will periodically review completed calculations for accuracy. These actions are intended to correct the issues that contributed to the calculation errors and delays noted during the audit and to ensure compliance with Return of Title IV Funds regulations moving forward.
The University concurs with the finding that the University does not have a written information security program that addresses all required elements of the Gramm-Leach-Bliley Act . While the University processes defined to address GLBA are in place, the Information Security Policy does not specific...
The University concurs with the finding that the University does not have a written information security program that addresses all required elements of the Gramm-Leach-Bliley Act . While the University processes defined to address GLBA are in place, the Information Security Policy does not specifically address Gramm-Leach-Bliley Act (GLBA) security criteria. It is now understood that the defined processes that address and support GLBA security criteria need to be put into a format that is published for access by the Lincoln community. Lincoln has started the process to create and publish the written information security program that addresses all required elements of GLBA. The corrective measures above are designed to ensure full compliance with all required elements of the GLBA.
The Office of Student Financial Services acknowledges the findings related to Reporting: Financial Reporting through the Common Origination and Disbursement (COD) System. We recognize the importance of accurate and timely reporting of origination data to ensure compliance with federal Pell Grant and...
The Office of Student Financial Services acknowledges the findings related to Reporting: Financial Reporting through the Common Origination and Disbursement (COD) System. We recognize the importance of accurate and timely reporting of origination data to ensure compliance with federal Pell Grant and Direct Loan requirements. The Office of Student Financial Services will implement additional controls to ensure accuracy of origination and disbursement reporting to COD. Prior to submission, staff will review enrollment dates, academic year dates, and disbursement dates against the academic calendar and student records in Colleague. A second-level review will be performed for a sample of records each term. Written procedures will be updated to document required verification steps before transmitting data to COD. Training will be provided to staff responsible for COD processing. These actions are intended to correct the issues contributing to this repeat finding, strengthen reporting accuracy, and ensure continued compliance with COD reporting requirements.
The University acknowledges the findings related to Special Tests: NSLDS Reporting. We recognize the importance of accurate and timely enrollment reporting to the National Student Loan Data System (NSLDS) to ensure proper administration of federal student aid programs. The institution reports enroll...
The University acknowledges the findings related to Special Tests: NSLDS Reporting. We recognize the importance of accurate and timely enrollment reporting to the National Student Loan Data System (NSLDS) to ensure proper administration of federal student aid programs. The institution reports enrollment and program information to NSLDS via the National Student Clearinghouse. The Student Clearinghouse offers a complimentary service for reviewing and correcting reporting issues for compliance. The office of the Registrar will engage the services of the Student Clearinghouse to identify where procedural errors may be causing delays or inaccuracies in the reporting data based on the findings of the 2025 audit. Recommendations made by the Student Clearinghouse consultant will be added into the documentation and standard practices for enrollment reporting. These actions are intended to correct the issues contributing to this repeat finding, strengthen reporting accuracy, and ensure continued compliance with NSLDS reporting requirements.
The Office of Student Financial Services acknowledges the finding and will implement corrective actions to ensure full compliance regarding Year-Round Pell Grant eligibility. To address the issue, enhanced processes and internal controls will be established to ensure all eligible students are accura...
The Office of Student Financial Services acknowledges the finding and will implement corrective actions to ensure full compliance regarding Year-Round Pell Grant eligibility. To address the issue, enhanced processes and internal controls will be established to ensure all eligible students are accurately identified for Summer Pell Grant disbursements. The Office of Student Financial Services will implement enhanced procedures to ensure all eligible students are properly identified for Year-Round Pell Grant awards. Each term, a review report will be generated to identify summer enrollees who received Pell Grant funding during the fall and/or spring terms. Financial aid staff will assess eligibility prior to disbursement by verifying enrollment intensity, cost of attendance, and remaining annual Pell eligibility. Written procedures will be updated to require a Pell eligibility review before processing any summer disbursements. The Director of Financial Aid will review the report each term to monitor compliance with these procedures.
Condition: Out of 40 students tested for Return to Title IV, we identified 3 students whose calculations were not performed timely. Planned Corrective Action: Financial Aid has reviewed our current practices and will implement centralized accountability processes, using the Banner system and associa...
Condition: Out of 40 students tested for Return to Title IV, we identified 3 students whose calculations were not performed timely. Planned Corrective Action: Financial Aid has reviewed our current practices and will implement centralized accountability processes, using the Banner system and associated reports, to monitor all types of student withdrawal and drop determinations, as well as the corresponding R2T4 deadlines. Standardized procedures and a comprehensive processing checklist will be developed to ensure accuracy and timely completion. Staff in both offices will be trained on the updated procedures. Financial Aid will also continue working with the Registrar’s Office to ensure the receipt of accurate and timely enrollment data necessary to meet all Title IV requirements and deadlines. Contact person responsible for corrective action: Shashanta S James, Director Lana Greaves, Sr. Associate Director Anticipated Completion Date: April 15, 2026
Condition: Of the 40 students selected for enrollment reporting testing, the University did not properly update the student enrollment information for 3 students accurately. Root Cause: Manual NSC updates were overwritten by subsequent certified enrollment files. Planned Corrective Action: Western M...
Condition: Of the 40 students selected for enrollment reporting testing, the University did not properly update the student enrollment information for 3 students accurately. Root Cause: Manual NSC updates were overwritten by subsequent certified enrollment files. Planned Corrective Action: Western Michigan University has discontinued the use of manual enrollment status updates in the NSC Student Look-Up tool for unofficial withdrawals. The Registrar’s Office now records last date of attendance and withdrawal status directly in the SIS for all students who earn all E and X grades and are determined to have unofficially withdrawn. All unofficial withdrawal records are included in the final enrollment submission for the term, ensuring that withdrawal status and effective dates are transmitted through certified batch files to NSC and NSLDS. Contact person responsible for corrective action: Registrar, Carrie Cumming Assistant Registrar of Academic Records, Nicole Miller Anticipated Completion Date: 08/20/2025 (This is the day we sent summer II 2025 final enrollment to the NSC. Summer II 2025 LDA changes were completed directly into the SIS.)
Campbellsville University acknowledges the reporting deficiency that occurred when certain clock-hour technical programs (Cosmetology, Barbering, Esthetics) were converted to a standard-term structure, and the Jenzabar extraction query was not updated. The University has updated affected student enr...
Campbellsville University acknowledges the reporting deficiency that occurred when certain clock-hour technical programs (Cosmetology, Barbering, Esthetics) were converted to a standard-term structure, and the Jenzabar extraction query was not updated. The University has updated affected student enrollment records, revised the extraction query and data mappings, and implemented a cross-department pre-reporting reconciliation between Institutional Research and Student Records. As part of this reconciliation, the Registrar’s Office completes a monthly internal check prior to sending the initial report, and any omitted students are reported directly to the National Student Clearinghouse (NSC). Additionally, Financial Aid and Student Records perform a post-NSLDS reporting audit on a random sample of students initially reported to NSC. All involved departments have instituted a temporary manual verification step while automated checks are finalized, and provided targeted staff training and updated procedures to strengthen change control for future program model changes. The Office of Financial Aid and Student Records will collaborate to resolve any student record discrepancies within NSLDS to make the necessary updates.
Condition: Northeastern Illinois University (University) did not have adequate procedures and controls in place to ensure student that unofficially withdrew during the semester were accurately reported to the National Student Loan Data System (NSLDS). Planned Corrective Action: Registrar’s office to...
Condition: Northeastern Illinois University (University) did not have adequate procedures and controls in place to ensure student that unofficially withdrew during the semester were accurately reported to the National Student Loan Data System (NSLDS). Planned Corrective Action: Registrar’s office to utilize the financial aid’s last date of attendance report and withdrawal determinations at the end of each semester to back date the effective enrollment reported date for unofficially withdrawn students at the end of each term. Contact person responsible for corrective action: Enrollment Management: Rahshida Walker, Registrar’s Office and Maureen Amos, Financial Aid Office Anticipated Completion Date: 6/30/2026
Action Taken: The Registrar's Office is working with the NSC administrator to address concerns with submitted reports being updated in NSLDS. Each error was corrected within the system. Going forward, the Registrar's Office is working with IT on updated internal reports to track and review the statu...
Action Taken: The Registrar's Office is working with the NSC administrator to address concerns with submitted reports being updated in NSLDS. Each error was corrected within the system. Going forward, the Registrar's Office is working with IT on updated internal reports to track and review the status changes and start dates to ensure they are being accurately reported. Responsible Individual for Corrective Action: Registrar - Jennifer Melon Anticipated Completion Date: June 30, 2026 If there are any questions regarding this corrective action plan, please call Jennifer Ginnetti, Sr. Associate VP/ Deputy CFO, at 215-641-5506 or email Ginnetti.j@gmercyu.edu.
Condition: Of the 40 students selected for enrollment reporting testing, 2 students did not have their status change updated appropriately and 3 students did not have their Classification of Instructional Programs (CIP) code updated appropriately. Planned Corrective Action: The Director of Student F...
Condition: Of the 40 students selected for enrollment reporting testing, 2 students did not have their status change updated appropriately and 3 students did not have their Classification of Instructional Programs (CIP) code updated appropriately. Planned Corrective Action: The Director of Student Financial Services now oversees enrollment reporting to the third-party servicer. The director reviews enrollment reporting to the third party and also reviews reporting to the third-party servicer to ensure accurate and timely reporting to NSLDS. Contact person responsible for corrective action: Callie Zake, Director of Student Financial Aid Anticipated Completion Date: June 19, 2026
Condition: Of the 40 students selected for enrollment reporting, the College did not update the student enrollment information for 3 students accurately. Planned Corrective Action: The College will modify its process and update its documented procedures to include periodically running an Enrollment ...
Condition: Of the 40 students selected for enrollment reporting, the College did not update the student enrollment information for 3 students accurately. Planned Corrective Action: The College will modify its process and update its documented procedures to include periodically running an Enrollment Reporting Graduated/Withdrawn Report from NLSDS and review for accuracy and make timely corrections, if necessary. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: June 30, 2026
Condition: The College did not have appropriate segregation of duties in place to ensure the reporting to COD is being reviewed by an individual separate from the process of preparing the reconciliations. Planned Corrective Action: The College will modify its process and update its documented proced...
Condition: The College did not have appropriate segregation of duties in place to ensure the reporting to COD is being reviewed by an individual separate from the process of preparing the reconciliations. Planned Corrective Action: The College will modify its process and update its documented procedures to include an appropriate review of the reconciliation by an individual separate from the process of preparing the reconciliations. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: June 30, 2026
Condition: The College did not provide notifications to certain students related to direct loan disbursements. Planned Corrective Action: The Director of Financial Aid will work with our information technology department to ensure the criteria used for triggering the notification emails is correct a...
Condition: The College did not provide notifications to certain students related to direct loan disbursements. Planned Corrective Action: The Director of Financial Aid will work with our information technology department to ensure the criteria used for triggering the notification emails is correct and capturing all the necessary students. Additionally, an exception report will be created to identify students who have not been sent the notification email for the financial aid department to review and then send the appropriate notification. The department procedures will be updated to reflect these changes in process. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: March 31, 2026
Condition: Out of 60 students tested for return to Title IV, we identified 4 students whose calculations were performed outside of the required time frame. Planned Corrective Action: The College will work with its Director of Financial Aid to ensure the semester end procedures include steps to ident...
Condition: Out of 60 students tested for return to Title IV, we identified 4 students whose calculations were performed outside of the required time frame. Planned Corrective Action: The College will work with its Director of Financial Aid to ensure the semester end procedures include steps to identify those students who unofficially withdrew. Once the students are identified, individuals with appropriate skills and knowledge will be able to determine if a return of Title IV calculation is necessary and appropriately return any funds, as necessary. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: March 31, 2026
The officials responsible for Student Accounts acknowledge that certain student financial aid refunds were processed outside the 14-day federal deadline, primarily due to insufficient Title IV training during the initial transfer of responsibilities to Student Accounts. While a standard operating pr...
The officials responsible for Student Accounts acknowledge that certain student financial aid refunds were processed outside the 14-day federal deadline, primarily due to insufficient Title IV training during the initial transfer of responsibilities to Student Accounts. While a standard operating procedures (SOP) exists within the current refunds training, it is limited, focusing primarily on the reports and some of federal requirements but does not provide sufficient detail on regulations, reviews, approvals, and timelines. Student Accounts has already taken steps to address and correct the misinformation, but additional improvements are still needed. The SOP for refunds is currently in progress to fully incorporate all necessary items to ensure better and clearer training guidelines. Mandatory Title IV refund training will be provided to all Refund Representatives and included in onboarding for new hire. We shall set established expectations set for all individuals involved in the process, including their delegates, to ensure accountability and consistent application of procedures. Ongoing collaboration with Financial Aid will ensure procedures are consistently applied, questions are addressed, and staff remain current with requirements. These actions are expected to ensure compliance with the 14-day federal requirement, strengthen staff competency, and support continuous improvement in refund processing. Person(s) Responsible: Student Accounts Manager (training), Associate Vice President & Controller Targeted Correction Date: June 30, 2026
At the end of the 2023–24 award year, responsibility for generating Return of Title IV (R2T4) withdrawal lists transitioned from the Business Office to the Financial Aid Office. The Financial Aid Office began producing both official withdrawal and unofficial (non-passing grade) reports through Elluc...
At the end of the 2023–24 award year, responsibility for generating Return of Title IV (R2T4) withdrawal lists transitioned from the Business Office to the Financial Aid Office. The Financial Aid Office began producing both official withdrawal and unofficial (non-passing grade) reports through Ellucian Banner. Because the two reports produced nearly identical student listings, it was assumed that the Banner-generated unofficial withdrawal report was effectively identifying all students who had received non-passing grades.During an internal audit conducted at the end of the Spring 2025 semester, the University identified one student who had failed all courses and was not included on either of the R2T4 lists. Upon further review, the issue was traced to a reporting limitation within Banner that excluded some students with all failing grades from the population used for R2T4 review. To resolve this, the Financial Aid Office coordinated with the Registrar’s Office to obtain a complete list of students who officially withdrew and students with all non-passing grades once final grades were submitted. R2T4 calculations were subsequently performed for applicable students identified in this additional list. Since Spring 2025, the University has institutionalized this revised procedure. The Registrar’s Office now provides the Financial Aid Office with a list of all students with non-passing grades at the end of each semester once grades are submitted. The Financial Aid Office reviews both reports to identify potential unofficial withdrawals and performs R2T4 calculations as required. To strengthen oversight and prevent future omissions during staffing transitions or process changes, the University will: • Document the revised R2T4 identification and review process in the Financial Aid operations manual. • Clearly assign responsibility for report generation, review, and follow-up between the Registrar’s Office and Financial Aid Office. • Implement a quarterly internal cross-check to confirm all required R2T4 reviews are completed. Person(s) Responsible: Associate Director of Financial Aid and Director of Financial Aid. Correction Date: January 31, 2026. This issue is resolved.
The University has made substantial progress toward completing the remaining elements required under the Gramm-Leach-Bliley Act (GLBA) and aligning its program with the FTC Safeguards Rule. Full implementation timelines are primarily constrained by current staffing capacity within ITS/Cybersecurity ...
The University has made substantial progress toward completing the remaining elements required under the Gramm-Leach-Bliley Act (GLBA) and aligning its program with the FTC Safeguards Rule. Full implementation timelines are primarily constrained by current staffing capacity within ITS/Cybersecurity and Legal, as well as certain technical tool limitations (e.g., data discovery and validation). Despite these constraints, notable progress has been achieved across the required FTC Safeguards Program elements as summarized below: • Element 1 – Designate a Qualified Individual: Completed. Qualified individual appointed to implement and supervise the company’s information security program; reporting mechanisms to the Board established. Completion is confirmed based on oversight and execution of subsequent program elements. • Element 2 – Conduct a Risk Assessment: Completed. Initial risk assessment conducted to identify reasonably foreseeable threats; controls and priorities for Elements 3–9 is being guided by this assessment. • Element 3 – Access Controls & Data Classification: 70% complete. Policies finalized; multi- factor authentication (MFA) implemented; initial asset inventory completed. Data owner assignments and detailed access reviews are in progress. • Element 4 – Vulnerability Management: Complete. Latest penetration testing identified no critical findings. • Element 5 – Information Security Policies: Drafted and pending Legal review; Board acceptance scheduled for March 2026. • Element 6 – Third-Party Oversight: 70% complete. Policy and workflow developed; Board acceptance scheduled for March 2026. • Element 7 – Periodic Risk Assessments: 80% complete. Updated risk assessment currently in progress. • Element 8 – Incident Response Plan: 90% complete. Final reporting and approval scheduled for March 2026. • Element 9 – Qualified Individual & Board Reporting: 90% complete. Annual report scheduled for March 2026. • Red Flags Rule (Identity Theft Prevention): 50% complete. Policy drafted, complete comprehensive program, formal procedures and additional trainings still required. Next Steps: Remaining actions will be completed as Legal and Board approvals are obtained and staffing capacity allows. HPU will continue to develop and retain documentation supporting the completion and implementation of each safeguard element, as prescribed by GLBA. Periodic internal assessments of the Information Security Program will be scheduled following full implementation, with consideration given to engaging an independent third party for future reviews. Person(s) Responsible: Information Security Officer; Vice President of Operations and Chief Information Officer. Targeted Correction Date: March 31, 2026.
The College will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.
The College will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.
The College will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.
The College will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.
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