Corrective Action Plans

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Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships; Dr. Lynda Batiste, Senior Vice President of Finance & Chief Operating Officer Corrective Action: With the implementation of Ellucian Colleague this issue has been resolved. The financial aid and ...
Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships; Dr. Lynda Batiste, Senior Vice President of Finance & Chief Operating Officer Corrective Action: With the implementation of Ellucian Colleague this issue has been resolved. The financial aid and business offices are directly involved with the COD processes weekly. This process sends originations and disbursement information for PELL and Federal loans to COD. Funds are transmitted to a student’s account through a two-part process called FATR between the two offices. With the implementation of Colleague, we have resolved those issues. Colleague's Financial Aid module provides the tools necessary to maintain, track, process, and report information associated with financial aid applicants and recipients to Colleague. The Financial Aid module helps manage the processing of financial aid, data, and reporting and will give SAU internal controls over their Title IV Student Financial Aid programs. Using this system, SAU can create and modify Grant records for submission to COD and import and reconcile Grant data. The financial aid office did not have these options in CAMS. The financial aid office no longer builds and or disburses aid manually in COD. Colleague and COD work together. The reconciliation process for Pell and Direct Loans to self-audit, ensuring the accuracy and validity of financial data sent and submitted to COD. The reconciliation process in completed monthly and any discrepancies are resolved prior to the next month. Anticipated Completion Date: December 31, 2023
Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: The financial aid department has developed a Direct Loan workflow process in accordance with federal guidelines. With the implementation of Colleague, this issue has been resolve...
Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: The financial aid department has developed a Direct Loan workflow process in accordance with federal guidelines. With the implementation of Colleague, this issue has been resolved. Utilizing Colleague's software, the financial aid office can now accurately assess our students' aid eligibility to ensure they are appropriately awarded. Colleague has Award Eligibility Criteria (AEC) rules invoked at transmittal to determine if the student is eligible to receive loan funds. Items this rule checks for include half-time enrollment, completion of Entrance Interview, Satisfactory Academic Progress, etc. AEC is primarily used as a criterion a student must pass before aid can be transmitted to Accounts Receivable. There are two sets of rules on the AEC form: Eligibility Criteria for Awarding and Eligibility Criteria for Transmitting. These rules monitor students' aggregate loan limits, SAP, as defined by Uniform Guidance rules and requirements for federal awards, and provide SAU with the internal controls needed for their Title IV program. The Financial Aid Director follows Ellucian Colleague’s best practice recommendations. Anticipated Completion Date: December 31, 2023
Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: Primarily the University implemented a robust ERP tool Ellucian Colleague that will assist in the administration and management of Title IV programs. COD processes are run throug...
Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: Primarily the University implemented a robust ERP tool Ellucian Colleague that will assist in the administration and management of Title IV programs. COD processes are run through Colleague's CODE (Common Originators Disbursement Ellucian) system, which is used to send origination requests and disbursement information for Pell and Federal loans to COD. Funds are transmitted to a student's account through a two-part process run between the Financial Aid Office (FAO) and the Business Office. The Finanical Aid Office is responsible for sending loan originations and disbursments to COD within 15 days. The data extraction process will be more consistent using the workflows provided by the new ERP system. Anticipated Completion Date: December 31, 2023
Name of Responsible Individual: Rita Archer, University Registrar, Office of the Registrar Corrective Action: Enrollment reporting is required for all schools participating in Title IV aid programs. Schools are required to certify enrollment for all students included on their roster files. SAU was ...
Name of Responsible Individual: Rita Archer, University Registrar, Office of the Registrar Corrective Action: Enrollment reporting is required for all schools participating in Title IV aid programs. Schools are required to certify enrollment for all students included on their roster files. SAU was without a Registrar during the 2019-2020 award year however, in August 2020 this position was filled. In addition more staff was hired to assist in these reporting functions. The Registrar had to submit the missing reports before submitting new ones. This backlog led to late status changes being reported. Primarily, the University implemented a comprehensive ERP software tool, Ellucian Colleague in FY2021 and FY2022 and hired more staff. The built-in internal control structure which includes access to enrollment reports and data coupled with a complete reconciliation process with the Office of Financial Aid, Office of the Registrar and Student Accounts will prevent this from recurring. Professional development is encouraged for the University’s staff to stay current on compliance, regulatory and legal guidelines and adopt industry best practices. Anticipated Completion Date: December 31, 2023
Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships; Dr. Lynda Batiste, Senior Vice President of Finance & Chief Operating Officer Corrective Action: Primarily the University implemented a robust ERP tool Ellucian Colleague that will assist in the a...
Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships; Dr. Lynda Batiste, Senior Vice President of Finance & Chief Operating Officer Corrective Action: Primarily the University implemented a robust ERP tool Ellucian Colleague that will assist in the administration and management of Title IV funds. This will include new workflows that have been added to the policies. Utilizing the workflows prescribed by Colleague the University will be able to work from reports to avoid these finding moving forward. In addition, the University contracted with Colleague for more formal training of all finance and financial aid employees. The FA Director and the Comptroller will work together weekly when disbursing funds. The Financial Aid Director will notify the Comptroller what amount is available to drawdown. Each area will complete their internal reconciliation. Effective June 2023 SAU is HCM2. Anticipated Completion Date: December 31, 2023
Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: With the implementation of Ellucian Colleague this issue has been resolved as the financial aid department can now track transfer students and any changes to their financial aid ...
Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: With the implementation of Ellucian Colleague this issue has been resolved as the financial aid department can now track transfer students and any changes to their financial aid while informing other institutions of those changes through the National Student Loan Data System (NSLDS). This issue has been resolved with the implementation of Colleague. The Financial Aid Director can now perform transfer monitoring in Colleague to track transfer students and any changes to their financial aid while informing other institutions of those changes. Colleague sends information files to the National Student Loan Data System (NSLDS), which notifies NSLDS of our transfer students and serves as a request to put SAU's transfer students on the NSLDS maintained Transfer Monitoring list. The inform file is also a request for a Financial Aid History file for each student listed. With Colleague, we can determine which students to monitor, send the information to NSLDS, transfer the files, and view students' NSLDS information as necessary. The Financial Aid Director runs transfer monitoring at the beginning of the semester for everyone enrolled and then runs TMXP, which creates a file to monitor those who are newly awarded, Students are run through the process in December for new transfer student can be monitored. With Colleague, the Financial Aid Director/Staff can easily adhere to the "Inform, Monitor, Alert" process since this system can efficiently and effectively run this process. Prior to awarding a transfer for spring the Financial Aid Staff as alternative option review NSLDS and manually add a student to the transfer monitoring file. Anticipated Completion Date: December 31, 2023
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.
View Audit 4064 Questioned Costs: $1
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Due to the College’s closure, there was no one remaining at the College with access to COD in order to gain access to the necessary information needed to complete the reconciliations.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.
Finding 2368 (2020-007)
Significant Deficiency 2021
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.
Finding 2367 (2020-006)
Significant Deficiency 2021
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations,...
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College )including key Information technology personnel). The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical financial information pertaining to the period under audit.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical financial information pertaining to the period under audit.
The University concurs with the finding. The University is currently utilizing the Banner Optimization to develop a message alert within the Student Portal (Wired) when a Graduation Fee is charged. This will be fully functional in FY25.
The University concurs with the finding. The University is currently utilizing the Banner Optimization to develop a message alert within the Student Portal (Wired) when a Graduation Fee is charged. This will be fully functional in FY25.
The University concurs with the finding The University is currently utilizing the Banner Optimization to develop a message alert within the Student Portal (Wired) when a withdrawal date is entered. This will be fully functional in FY25.
The University concurs with the finding The University is currently utilizing the Banner Optimization to develop a message alert within the Student Portal (Wired) when a withdrawal date is entered. This will be fully functional in FY25.
The University concurs with the finding. The University is currently utilizing the Banner Optimization to refine that all withdrawn students are included in the Summary Level Report. This will be fully functional in FY25.
The University concurs with the finding. The University is currently utilizing the Banner Optimization to refine that all withdrawn students are included in the Summary Level Report. This will be fully functional in FY25.
The University concurs with the finding. The University is currently utilizing the Banner Optimization to develop a message alert within the Student Portal (Wired) when a loan disbursement is made. This will be fully functional in FY25.
The University concurs with the finding. The University is currently utilizing the Banner Optimization to develop a message alert within the Student Portal (Wired) when a loan disbursement is made. This will be fully functional in FY25.
The University concurs with finding. All students were reported to the National Student Clearinghouse (NSC) as to what their status was for those terms. The updates were not updated in the NSLDS side. According to the audit staff, this is a common finding amongst institution due to this being a fair...
The University concurs with finding. All students were reported to the National Student Clearinghouse (NSC) as to what their status was for those terms. The updates were not updated in the NSLDS side. According to the audit staff, this is a common finding amongst institution due to this being a fairly new process/requirement. This process will be corrected going forward.
The University concurs with finding. All students were reported to the National Student Clearinghouse (NSC) as to what their status was for those terms. The updates were not updated in the NSLDS side. According to the audit staff, this is a common finding amongst institution due to this being a fair...
The University concurs with finding. All students were reported to the National Student Clearinghouse (NSC) as to what their status was for those terms. The updates were not updated in the NSLDS side. According to the audit staff, this is a common finding amongst institution due to this being a fairly new process/requirement. This process will be corrected going forward.
Corrective Action: The University Financial Aid Office moved the beginning time for disbursement up from 11:50 PM to 8:00 PM on our large disbursement days to allow time for that process to run within Banner and complete well before midnight ensuring a date match between UCM and COD. Anticipated Com...
Corrective Action: The University Financial Aid Office moved the beginning time for disbursement up from 11:50 PM to 8:00 PM on our large disbursement days to allow time for that process to run within Banner and complete well before midnight ensuring a date match between UCM and COD. Anticipated Completion Date: August 2020 (prior to Fall 2020 disbursement date). Contact Person: Tony Lubbers, Financial Aid Director.
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