Corrective Action Plans

Finding 5965 (2022-119)

Material Weakness 2022

State of Arizona

AZ

Subrecipient Monitoring Internal Control / Segregation of Duties Student Financial Aid

Assistance listing number and program name: 93.658 Foster Care – Title IV-E 93.658 COVID-19 Foster Care - Title IV-E Agency: Department of Child Safety Name of contact person and title: Emilio Gonzales, Audit Administrator Completion date: June 30, 2024 Agency’s Response: Concur The Department w...

Assistance listing number and program name: 93.658 Foster Care – Title IV-E 93.658 COVID-19 Foster Care - Title IV-E Agency: Department of Child Safety Name of contact person and title: Emilio Gonzales, Audit Administrator Completion date: June 30, 2024 Agency’s Response: Concur The Department will comply with the Federal Funding Accountability and Transparency Act (FFATA) and federal Uniform Guidance regulations in accordance with the Department’s Grant policies and procedures that include: • Identifying all subrecipient expenditure reports required for FFATA reporting. • Developing an expenditure template for the Federal Funding Accountability and Transparency Subaward Reporting System (FSRS). • Reporting the subrecipient expenditures in the FFATA Subaward Reporting System no later than month-end of the month following the subaward action. • Providing initial and annual training(s) to identified staff about FFATA Subaward expenditure submission. • Confirming FFATA Subaward Reporting System submission.

View Audit 7884

Finding 5959 (2022-117)

Material Weakness 2022

State of Arizona

AZ

Student Financial Aid Eligibility Internal Control / Segregation of Duties

Assistance listing number and program name: 93.658 Foster Care – Title IV-E Agency: Department of Child Safety Name of contact person and title: Tanya Abdellatif, Assistant Director Anticipated completion date: June 30, 2025 Agency’s Response: Concur Department will ensure background checks for ch...

Assistance listing number and program name: 93.658 Foster Care – Title IV-E Agency: Department of Child Safety Name of contact person and title: Tanya Abdellatif, Assistant Director Anticipated completion date: June 30, 2025 Agency’s Response: Concur Department will ensure background checks for childcare institutions’ employees are completed prior to their hire date by: • Reviewing and amending DCS 15-32 Background Checks – Child Welfare Agency Staff policy and procedures to clarify that Child Welfare Agencies shall request and receive results for DCS Central Registry background checks prior to employment/date of hire. • Revising the Personnel File Monitoring Tool for licensing to include language that background checks need to be completed prior to hire and ensure all Child Welfare Licensing staff are utilizing the updated checklist. • Implementing, as part of the Quarterly Site Visit Process for childcare institutions, a process to review backgrounds checks to identify opportunities for improvement, trends and establish actions (countermeasures) to resolve any areas of concern. Hiring processes for each agency will also be reviewed during the quarterly site visits. • Providing updates related to policies and procedures during Quarterly Provider Meetings for childcare institutions, implementing monthly provider calls/meetings and conducting monthly unit/team meetings for Department. • Presenting the safety requirement expectations related to background checks for employees to childcare institutions and how the safety requirements are necessary for foster care maintenance payments at a quarterly meeting. • Conducting monthly monitoring of childcare institutions’ compliance with safety requirement expectations (background checks) for new and existing employees for fiscal year 2023.

View Audit 7884

Finding 5930 (2022-126)

Significant Deficiency 2022

State of Arizona

AZ

Questioned Costs Student Financial Aid Eligibility § 200.303

Assistance listing number and program name: 84.425E COVID-19 Education Stabilization Fund—Higher Education Emergency Relief Fund (HEERF)—Student Portion Student Financial Assistance Cluster 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study 84.038 Federal Perkins L...

Assistance listing number and program name: 84.425E COVID-19 Education Stabilization Fund—Higher Education Emergency Relief Fund (HEERF)—Student Portion Student Financial Assistance Cluster 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study 84.038 Federal Perkins Loan Program—Federal Capital Contributions 84.063 Federal Pell Grant Programs 84.268 Federal Direct Student Loans 84.379 Teacher Education Assistance for College and Higher Education Grants (TEACH Grants) 93.364 Nursing Student Loans 93.925 Scholarships for Health Professions Students from Disadvantaged Backgrounds—Scholarships for Disadvantaged Students (SDS) Agency: Northern Arizona University (NAA) Name of contact person and title: Bradley Miner, Interim Associate Vice President and Comptroller Anticipated completion date: November 30, 2023 Agency’s Response: Concur See University response section at the end of this report for the corrective action response for finding 2022-126.

View Audit 7884 Questioned Costs: $1

Finding 3916 (2022-009)

Material Weakness 2022

Union Theological Seminary in the City of New York

NY

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

This Repeat Finding has been acknowledged and corrective action is already in the process of being implemented. In November 2022, Union signed a Master Service Agreement with the National Student Clearinghouse (NSC) to perform enrollment and educational financial industry reporting, as well as edu...

This Repeat Finding has been acknowledged and corrective action is already in the process of being implemented. In November 2022, Union signed a Master Service Agreement with the National Student Clearinghouse (NSC) to perform enrollment and educational financial industry reporting, as well as education verification and authentication services. National Clearinghouse is the leading provider of educational reporting and data exchange, reporting on 97% of post-secondary student enrollments in the US. Union will be using a secure FTP process to send our enrollment data to NSC for timely and consistent reporting to the National Student Loan Data System (NSLDS). This Spring, Union completed the initial portion of the implementation by uploading a base set of enrollment data to NSC using Spring 2023 enrollment information. This was followed by one round of data clean-up. A second set of enrollment data was transmitted in December 2023. The Registrar and Financial Aid Director have been provided direct access to both NSC and NSLDS. As a backup, the Associate Dean of Academic Administration and Vice President of Admissions and Financial Aid have been granted NSC login credentials in order to ensure continuity of reporting in case of employee absence. The Registrar’s Office plans to begin regular monthly uploads of enrollment data to NSC beginning January 2024.

View Audit 6166

Finding 3388 (2022-013)

None 2022

City of Philadelphia

PA

Questioned Costs Student Financial Aid Cash Management

Children and Youth Programs Assistance Listing 93.090 Guardianship Assistance Assistance Listing 93.645 Stephanie Tubbs Jones Child Welfare Services Program Assistance Listing 93.658 Foster Care Title IV-E Assistance Listing 93.659 Adoption Assistance Assistance Listing 93.778 Medical Assistance Pro...

Children and Youth Programs Assistance Listing 93.090 Guardianship Assistance Assistance Listing 93.645 Stephanie Tubbs Jones Child Welfare Services Program Assistance Listing 93.658 Foster Care Title IV-E Assistance Listing 93.659 Adoption Assistance Assistance Listing 93.778 Medical Assistance Program Assistance Listing 93.556 MaryLee Allen Promoting Safe and Stable Families Program Act 148 Pennsylvania Department of Human Services Views of the Responsible Officials and Corrective Action Plan: After a recent discussion with the [PA] Office of Children, Youth, and Families (OCYF), DHS was informed that compensation plans for FY21 and FY22 were on file and under review. However, approval was pending. OCYF explained that the State reviews plans on a calendar-year basis. However, city pay plans change during a July-June fiscal year. Therefore, the possibility of overages can occur because of salary increases or other personnel changes. The process is that once the new compensation plan is received, the reviewing authority would flag any items that are in excess of the existing approved rates. At that time, DHS would be permitted to submit a waiver for the items in question. Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.

View Audit 5296 Questioned Costs: $1

Finding 2358 (2022-003)

None 2022

Contemporary Oriental Medicine Foundation

FL

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

A. Comments on Findings and Recommendations: 2022-003 – INCORRECT REFUND CALCULATION We agree with the finding for an incorrect refund calculation. B. Actions Taken or Planned: 2022-003 – INCORRECT REFUND CALCULATION The refund was calculated incorrectly and was caused by not including a scheduled b...

A. Comments on Findings and Recommendations: 2022-003 – INCORRECT REFUND CALCULATION We agree with the finding for an incorrect refund calculation. B. Actions Taken or Planned: 2022-003 – INCORRECT REFUND CALCULATION The refund was calculated incorrectly and was caused by not including a scheduled break of 5 days or more due to the Thanksgiving holiday. This resulted in a refund being transmitted to the Department of Education that should have been retained by the college. The college will credit the $196 to the student’s account and in the future, a more thorough cross-check of the R2T4 will be performed by the Financial Aid office before processing the refund.

View Audit 4043

Finding 2357 (2022-002)

Material Weakness 2022

Contemporary Oriental Medicine Foundation

FL

Reporting Matching / Level of Effort / Earmarking Student Financial Aid

A. Comments on Findings and Recommendations: 2022-002 – LATE AUDIT We agree with the finding for a late audit. B. Actions Taken or Planned: 2022-002 – LATE AUDIT The Board’s Treasurer for 2022 was unable to assist with the 2022 audit due to a health concern. There was delay in getting the informatio...

A. Comments on Findings and Recommendations: 2022-002 – LATE AUDIT We agree with the finding for a late audit. B. Actions Taken or Planned: 2022-002 – LATE AUDIT The Board’s Treasurer for 2022 was unable to assist with the 2022 audit due to a health concern. There was delay in getting the information needed to finalize the financial audit, which then delayed the federal direct loan program audit. This has been rectified with a former Board Treasurer rejoining the Board who has experience from prior years. The college will implement the necessary procedures to prevent future audits from being submitted late.

View Audit 4043

Finding 2356 (2022-001)

Material Weakness 2022

Contemporary Oriental Medicine Foundation

FL

Student Financial Aid Matching / Level of Effort / Earmarking

A. Comments on Findings and Recommendations: 2022-001 – FINANCIAL RESPONSIBILITY We agree with the finding for not meeting the minimum financial standards set forth by the DOE. B. Actions Taken or Planned: 2022-001 - FINANCIAL RESPONSIBILITY The organization incurred a net loss for the year as a res...

A. Comments on Findings and Recommendations: 2022-001 – FINANCIAL RESPONSIBILITY We agree with the finding for not meeting the minimum financial standards set forth by the DOE. B. Actions Taken or Planned: 2022-001 - FINANCIAL RESPONSIBILITY The organization incurred a net loss for the year as a result of additional expenditures related to opening a second location in Bradenton, Florida, and we don’t anticipate these additional expenditures in 2023. We anticipate having operations returning to normal and growing our enrollment with the addition of a second location.

View Audit 4043

Finding 2285 (2022-002)

Significant Deficiency 2022

Boston Architectural College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Management’s Corrective Action Plan Finding number: 2022-002 Federal agency: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing #’s 84.063, 84.268 Award year: 2022 Corrective Action Plan The BAC will augment last year’s monthly automation of ros...

Management’s Corrective Action Plan Finding number: 2022-002 Federal agency: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing #’s 84.063, 84.268 Award year: 2022 Corrective Action Plan The BAC will augment last year’s monthly automation of roster submission with a monthly reconciliation of enrolment status as recorded in our student information system with the data recorded in NSLDS. Management will provide training to those reasonable for reporting enrolment status to NSLDS via the National Student Clearinghouse. This training will include the relevant rules and regulations as well as stress the importance of accuracy and the potential consequences of errors, both to our students and the institution. Timeline for Implementation of Corrective Action Plan The College plans to implement the corrective action plan by October 1, 2023. Contact Person James Ryan, Ph.D. Vice President of Enrollment Management

View Audit 3923

Finding 1764 (2022-009)

Material Weakness 2022

Arkansas Baptist College

AR

Questioned Costs Student Financial Aid Subrecipient Monitoring

Arkansas Baptist College disagrees with the finding. NSLDS confirms that the student had not exceeded her Lifetime Eligibility of 600%. She used 571.765% of the 600% she was eligible to receive. Although NSLDS indicates her scheduled award amount is $6,495, she would exceed 600% if awarded the fu...

Arkansas Baptist College disagrees with the finding. NSLDS confirms that the student had not exceeded her Lifetime Eligibility of 600%. She used 571.765% of the 600% she was eligible to receive. Although NSLDS indicates her scheduled award amount is $6,495, she would exceed 600% if awarded the full amount. She was awarded $1,624 which brings per Pell Grant Annual and Lifetime Eligibility to 600%.

View Audit 3046 Questioned Costs: $1

Finding 1760 (2022-008)

Material Weakness 2022

Arkansas Baptist College

AR

Questioned Costs Student Financial Aid Eligibility

Arkansas Baptist College agrees with the finding however the over awards were created by an outside scholarship after the award process ended. Arkansas Baptist College will revise financial aid awards to include outside scholarships and eliminate over awards.

View Audit 3046 Questioned Costs: $1

Finding 1758 (2022-007)

Material Weakness 2022

Arkansas Baptist College

AR

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Management does not agree with the auditor as the Department of Education Payment Analysis verifies the amount requested on Form 270 and approves payment as requested. A subsequent adjustment to a student’s financial aid does not affect the original 270. Every financial aid draw is based on known...

Management does not agree with the auditor as the Department of Education Payment Analysis verifies the amount requested on Form 270 and approves payment as requested. A subsequent adjustment to a student’s financial aid does not affect the original 270. Every financial aid draw is based on known facts as of that date.

View Audit 3046

Finding 1757 (2022-006)

Material Weakness 2022

Arkansas Baptist College

AR

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Arkansas Baptist college concur with this finding. Careful attention will be given to all other ineligible applicants to ensure that they are eligible before packing.

View Audit 3046 Questioned Costs: $1

Finding 1756 (2022-005)

Material Weakness 2022

Arkansas Baptist College

AR

Student Financial Aid Subrecipient Monitoring Matching / Level of Effort / Earmarking

Arkansas Baptist College do not agree with the findings. Arkansas Baptist College provided the correct information to the auditor. The information was extracted directly from the Clearinghouse.

View Audit 3046

Finding 1754 (2022-004)

Material Weakness 2022

Arkansas Baptist College

AR

Student Financial Aid Subrecipient Monitoring Reporting

Arkansas Baptist College will implement controls to ensure that the FISAP is prepared correctly with supporting documents.

View Audit 3046

Finding 1752 (2022-003)

Material Weakness 2022

Arkansas Baptist College

AR

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Management concurs with this finding. Management will continue to train in Financial Aid and Business office.

View Audit 3046

Finding 1750 (2022-002)

Material Weakness 2022

Arkansas Baptist College

AR

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Management will make every effort to accurately complete R2T4 and return funds to COD as appropriate and in a timely manner. Management will use COD software to correctly calculate R2T4.

View Audit 3046 Questioned Costs: $1

Finding 1358 (2022-002)

Material Weakness 2022

Goddard College Corporation

VT

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Finding: 2022-002 Enrollment Reporting Person Responsible for Corrective Action: Registrar Corrective Action Plan: The registrar reports enrollment via the National Student Clearinghouse (NSLC). During the period under review there was a technical issue in the submission of the files to the clearing...

Finding: 2022-002 Enrollment Reporting Person Responsible for Corrective Action: Registrar Corrective Action Plan: The registrar reports enrollment via the National Student Clearinghouse (NSLC). During the period under review there was a technical issue in the submission of the files to the clearinghouse. Goddard’s information technology team created a new submission file format and once that was completed the files were uploaded to the clearinghouse. The registrar will continue to monitor email submission statuses and the information technology team will assist in the event of technical issues. Goddard College is implementing a new student information system that is configured to the clearinghouse enrollment reporting & degree verify standards. The college will be better able to remain compliant and will reduce the chances of technical errors. Additionally, as NSLC makes changes in reporting, the college will also be able to easily make adjustments in the new system. Anticipated Completion Date: Complete

View Audit 2545

Finding 855 (2022-002)

None 2022

Helene Fuld College of Nursing

NY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

The College agrees with the finding and recommendations. The College uses the updated policy and procedure manual to conduct the enrollment reporting. The Office of Registrar was restructured. Two new Registrar Officials were hired in January 2022 and received training from NSLDS. From February 2022...

The College agrees with the finding and recommendations. The College uses the updated policy and procedure manual to conduct the enrollment reporting. The Office of Registrar was restructured. Two new Registrar Officials were hired in January 2022 and received training from NSLDS. From February 2022 to April 2022 a comprehensive review and update of all students was completed. As of the completion of comprehensive review, the enrollment reporting process has been conducted every thirty days during the first week of the month. In addition to the policies and procedures referenced in last year’s management response, the College has implemented an internal audit to take place every three months to reconcile NSLDS to the Helene Fuld Student record. This process allows the College to identify any discrepancies and update student records timely. The above procedures are now in effect as of January 31, 2022.

View Audit 1636

Finding 854 (2022-001)

None 2022

Helene Fuld College of Nursing

NY

Student Financial Aid Matching / Level of Effort / Earmarking

Since the fall of 2022, when these incidents occurred, the College has worked regularly with BPS, its financial aid consultant, to make sure all awards are compliant and to provide appropriate training to the College’s financial aid staff. The training is continuous and is being done by both BPS an...

Since the fall of 2022, when these incidents occurred, the College has worked regularly with BPS, its financial aid consultant, to make sure all awards are compliant and to provide appropriate training to the College’s financial aid staff. The training is continuous and is being done by both BPS and Ms. Joanna Ojada, who is now the Vice President of Student Services. Last fall, the President centralized all responsibility for financial aid under Ms. Ojada. Ms. Ojada is now responsible for all award compliance. In addition, the College is in the process of purchasing upgraded financial aid modules from Anthology. These modules will automate much of the financial aid processing and reduce the risk of manual error. The College has reached out to the Department of Education to discuss these over awards. The Department has advised the College that the College does not need to return the funds or to open up prior award years. The Department will enforce the loans against the students.

View Audit 1636

Finding 513713 (2021-013)

Material Weakness 2021

Wyoming County

PA

Reporting Student Financial Aid Subrecipient Monitoring

Community Development Block Grant - Assistance Listing No. 14.228 passed through the Pennsylvania Department of Community and Economic Development - Pass-through Grantor’s Numbers - C000061477, C000063292, C000065043; C000070006; COVID-19 Emergency Rental Assistance Program - Assistance Listing No. ...

Community Development Block Grant - Assistance Listing No. 14.228 passed through the Pennsylvania Department of Community and Economic Development - Pass-through Grantor’s Numbers - C000061477, C000063292, C000065043; C000070006; COVID-19 Emergency Rental Assistance Program - Assistance Listing No. 21.023 passed through the Pennsylvania Department of Human Services; Hazard Mitigation Grant - Assistance Listing No. 97.039 passed through the Pennsylvania Emergency Management Agency - Pass-through Grantor’s Number - 4100085508; Grant Period - Year Ended December 31, 2021. Recommendation: The individuals who prepare and review the SEFA should ensure it meets the Uniform Guidance schedule requirements. Planned Corrective Action: SEFA will meet Uniform Guidance Schedule Requirements Person Responsible: Amber Franko, Chief Clerk Anticipated completion date: Immediately

View Audit 331626

Finding 371939 (2021-004)

Significant Deficiency 2021

Martin University

IN

Matching / Level of Effort / Earmarking Student Financial Aid

Procedures used to identify students for the return of Title IV funds should be improved student financial aid cluster program. Corrective action: The University has implemented policy and procedures that require a review of all official and unofficial withdrawals to have R2T4 calculations on a real...

Procedures used to identify students for the return of Title IV funds should be improved student financial aid cluster program. Corrective action: The University has implemented policy and procedures that require a review of all official and unofficial withdrawals to have R2T4 calculations on a real time basis to ensure compliance with the Department of Education guidelines on a consistent and regular basis. Internal audits of the process will also be implemented for continuous improvement. Person responsible: Qiana Hall, Associate VP of Enrollment Services Anticipated Completion Date: March 31, 2024

View Audit 293212

Finding 371938 (2021-003)

Significant Deficiency 2021

Martin University

IN

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility

Enrollment reporting procedures should be strengthened Corrective action: The University submitted a correction action plan that was acceptable by DOE. and implemented effective 9/1/2022. Person responsible: Qiana Hall, Associate VP of Enrollment Services Anticipated Completion Date: Completed

View Audit 293212

Finding 369290 (2021-025)

None 2021

Saint Augustine's University

NC

Student Financial Aid Eligibility Internal Control / Segregation of Duties

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: The University contracted with Inceptia on 2/5/2020, and Inceptia started completing verification for SAU on 2/18/2020. Inceptia' s Verification Gateway platform provides an auto...

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: The University contracted with Inceptia on 2/5/2020, and Inceptia started completing verification for SAU on 2/18/2020. Inceptia' s Verification Gateway platform provides an automated solution to gather information and documentation required for Financial Aid Verification. Inceptia uses innovative technology to apply progressive rules for automatically or manually approving verification. Furthermore, it provides efficient and effective processes to help institutions remain compliant by organizing documents, streamlining award packaging, and allowing staff to manage the verification process. It provides the institution with the internal controls it needs over its Title IV funding. The Financial Aid Staff also can manually verify students if needed. With Colleague and Inceptia, SAU now has a more unified operating system for systematic processes. If a student has been flagged for verification, Colleague will not allow staff to award the student financial aid. One of the award eligibility rules is "Verification Complete." If students fail to pass this rule, they will not be awarded financial aid. Colleague gives the Financial Aid Staff greater control over the disbursal of Title IV funds and prevents the FAO from disbursing aid to students who are ineligible to receive it. Anticipated Completion Date: December 31, 2023

View Audit 290538

Finding 369288 (2021-023)

Material Weakness 2021

Saint Augustine's University

NC

Internal Control / Segregation of Duties Student Financial Aid Matching / Level of Effort / Earmarking

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: Primarily, the University implemented a comprehensive ERP software tool, Ellucian Colleague in FY2022 going forward. The built in internal control will readily provide data on th...

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: Primarily, the University implemented a comprehensive ERP software tool, Ellucian Colleague in FY2022 going forward. The built in internal control will readily provide data on those students who are eligible for aid and notify them of their opportunity to accept or decline aid. In addition, the notification documents will be stored in the ERP system and be available to retrieve. Within 15 days after disbursements students and parents are sent an email notifying them their loan has been disbursed to their account. Anticipated Completion Date: December 31, 2023

View Audit 290538

Corrective Action Plans

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