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Corrective Action Plan December 16, 2022 Cognizant or Oversight Agency for Audit Labette Community College respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Jarred, Gilmore & Phillips, PA, P.O. Box 779...
Corrective Action Plan December 16, 2022 Cognizant or Oversight Agency for Audit Labette Community College respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Jarred, Gilmore & Phillips, PA, P.O. Box 779, 1815 S Santa Fe, Chanute, Kansas 66720. Audit period: Year ended June 30, 2022. The findings from the December 16, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding: 2022-001 ? Special Tests and Provisions ? Return of Title IV Funds Condition: The date of the institution?s determination of a student?s withdrawal is the date the student began the official withdrawal process or the date of the student?s notification, whichever is later. During our testing of the withdrawn students, it was noted that Labette Community College did not use the correct determination date when calculating the return of Title IV funds. Recommendation: Policies and procedures should be written and additional training should be understanding of the institution?s date of determination of a student?s withdrawal. Views of responsible officials and planned corrective action: New staff continue to be trained and are learning the rules and regulations with Title IV Funding. We have also added this to a R2T4 checklist staff use to ensure there are no more errors when reporting the date of the school?s determination on the R2T4. If the Oversight Agency for Audit has questions regarding this plan, please call Leanna Doherty, Vice President of Finance and Operations, at (620) 820-1231. Sincerely, Labette Community College Labette Community College
Responsible Individuals: Lori Herrick, CPA, CFE - Associate Vice President of Finance Dr. Eric Gumm - Registrar and Director of the First-Year Program and Academic Development Center Finding 2022-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Clu...
Responsible Individuals: Lori Herrick, CPA, CFE - Associate Vice President of Finance Dr. Eric Gumm - Registrar and Director of the First-Year Program and Academic Development Center Finding 2022-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster CFDA #84.063, 84.268 Finding Summary: In accordance with 34 CFR sections 690.93(b)(2), 682.610, and 685.309(i), Federal Regulations state that institutions are required to report enrollment information. Out of a sample size of 25 students, there were 19 students identified as not having an incorrect Program Enrollment Effective Date and 3 students in which the update for enrollment status was not timely. Corrective Action Plan (CAP): ACU has identified the source and cause of the variance in the program enrollment effective date. The variance is due to the time stamp associated with certain actions within the Banner reporting system. Immediate implementation of system process to change the time status upon the appropriate enrollment change has corrected this error and the timely reporting of status changes. Anticipated Completion Date: The updated procedure was implemented by the beginning of Fall 2022. Responsible Parties: Dr. Eric Gumm is the responsible party as the University Registrar. He will oversee the execution of the corrective action plan. J Rodriquez is the Assistant Registrar and the responsible part for the implementation and execution of the corrective action plan.
Return of Title IV (R2T4) Calculations Planned Corrective Action: Our process for identifying unofficial withdrawals has been to nm a report through our Workday software to identify students who had unearned credits in a semester at the conclusion of that semester, after the grade due date. We...
Return of Title IV (R2T4) Calculations Planned Corrective Action: Our process for identifying unofficial withdrawals has been to nm a report through our Workday software to identify students who had unearned credits in a semester at the conclusion of that semester, after the grade due date. We would then reach out to the individual professors of the courses to determine if each student completed the semester or if they had unearned credits because they ceased attending at some point during the semester. If they ceased attending, we would determine if a Return of Title IV (R2T4) Calculation was needed and would complete it if necessary. In preparing for the Al 33 audit, the auditor requested: "If you have online or modular students, please provide a list of students who earned 0 credits or no showed in at least one of the online classes or modules from the registrar." While pulling together the list of students to send to the auditors, we determined that the repo11 we were using to identify unofficial withdrawals did not include students who had No Credit (NC) grades or Incomplete (I) grades. It was only pulling Failed (F) grades. In addition, the report only included students who had received F grades in all the courses for the semester; it did not include students who received 0 credits in one of the modules. The report was corrected and should enable PLNU to identify all the students who need to be reviewed going forward. In addition, we have added to our process instructions to run this report after the grades for module I are due, and after the grades for module 2 are due, rather than at the end of each semester. This will ensure that we catch any unofficial withdrawals in a timelier manner and will allow us to meet the 45-day deadline for any possible returns that must be made. Person Responsible for Corrective Action Plan: Jamie Asche, Director of Financial Aid Anticipated Date of Completion: 11/30/2022
Name of Responsible Individual(s): Stacey Brackett, University Registrar Corrective Action: The University has modified reporting practices to SSCR in order to meet Federal Regulations 34 CFR 690.83(b)(2), 34 CFR 682.610 and 34 CFR 685.309. The Office of Academic Records will report student enrollme...
Name of Responsible Individual(s): Stacey Brackett, University Registrar Corrective Action: The University has modified reporting practices to SSCR in order to meet Federal Regulations 34 CFR 690.83(b)(2), 34 CFR 682.610 and 34 CFR 685.309. The Office of Academic Records will report student enrollment to SSCR on the 15th of every month (or the following business day if the 15th falls on a weekend, holiday or scheduled university closure). This plan will allow for reporting from SSCR to NSLDS to meet the 60 day timeline for student status change. The University has also strengthened report criteria to ensure that all current program and major detail are provided to SSCR. Anticipated Completion Date: 12/31/2022
Name of Responsible Individual(s): Courtney Thompson, Director of Financial Aid Corrective Action: The University has reviewed current practices related to withdrawal/R2T4 calculations. As a result, the University will enhance current policy and procedures to better support staff in the proper calc...
Name of Responsible Individual(s): Courtney Thompson, Director of Financial Aid Corrective Action: The University has reviewed current practices related to withdrawal/R2T4 calculations. As a result, the University will enhance current policy and procedures to better support staff in the proper calculation of return of Title IV funds requirements. These enhancements will include but are not limited to; additional staff training and periodic secondary review. The Office of Financial Aid will also work with the Office of Academic Records to document substantiated last dates of attendance for withdrawing students. Anticipated Completion Date: 5/31/2022
Finding 43561 (2022-003)
Significant Deficiency 2022
2022-003 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, 84.038 Grant Period - Year Ended June 30, 2022 ...
2022-003 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, 84.038 Grant Period - Year Ended June 30, 2022 Condition Found During our student file testing we noted four students out of forty were not disbursed the correct Direct Loans award. Based on the student?s enrollment status and need, the College over awarded Direct Loans to the students by $2,993. We consider this to be a significant deficiency relating to the Eligibility Compliance Requirement. Corrective Action Plan Due to the institutional policy, we have updated our process to check and recalculate all loans for the current semester in the following semester by the census date. Responsible Person for Corrective Action Plan Jeremy Hurse ? Director of Student Financial Services Deborah Beck ? Associate Director of Student Financial Services Implementation Date of Corrective Action Plan 01/16/2023
View Audit 44632 Questioned Costs: $1
2022-002: Missing Exit Counseling Documentation - Student Financial Aid Cluster - Assistance Listing #s 84.033, 84.007, 84.063, 84.268, 84.038 - Grant Period - Year Ended June 30, 2022 ...
2022-002: Missing Exit Counseling Documentation - Student Financial Aid Cluster - Assistance Listing #s 84.033, 84.007, 84.063, 84.268, 84.038 - Grant Period - Year Ended June 30, 2022 Condition Found During our student file testing, we noted three students out of forty did not have documentation in their file that exit counseling was sent thirty days after the student withdrew from the College. We consider the missing exit counseling to be an instance of non-compliance with the Eligibility Compliance Requirement. Corrective Action Plan We have updated our process to check for any students who have withdrawn from the institution. After speaking with the registrar?s office, we are creating a report that will provide us with the withdrawal date so we may begin notifying students of their requirement for exit counseling. Responsible Person for Corrective Action Plan Jeremy Hurse ? Director of Student Financial Services Deborah Beck ? Associate Director of Student Financial Services Implementation Date of Corrective Action Plan 01/16/2023
Federal Perkins Loans ? Assistance Listing No.: 84.038 Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the ...
Federal Perkins Loans ? Assistance Listing No.: 84.038 Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All Perkins funds were audited in FY21 and we acknowledge that there are some files with missing MPNs. All the files have either been purchased from DOE or are currently receiving active payments. If payments do not remain current, we assign these loans to DOE after one year. There is no opportunity to recreate MPNs on these old loans, so no corrective action is possible. Name of the contact person responsible for corrective action: Michelle Hegarty, CFO Planned completion date for corrective action plan: December 2021
Student Financial Aid Cluster ? Assistance Listing No.: Various Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Explanation of disagreement with a...
Student Financial Aid Cluster ? Assistance Listing No.: Various Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar will be taking over all submissions going forward to ensure timely and accurate responses. Name of the contact person responsible for corrective action: Kris Ragozzino, Registrar Planned completion date for corrective action plan: May 1, 2023
Student Financial Aid Cluster ? Assistance Listing No.: Various Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the "Campus Level" and "Program Level". Explanation of disagreement with audit fin...
Student Financial Aid Cluster ? Assistance Listing No.: Various Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the "Campus Level" and "Program Level". Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We report directly to the National Student Clearing house and rely on their punctuality in forwarding our report to NSLDS. On an institutional level, graduation processes have been modified to include secondary verification of graduate files. Monthly audits are performed to monitor report results. If errors are discovered during the audit, updates will be made to the report prior to sending to the National Student Clearinghouse and the report will be corrected. Lastly, when a new employee accidently makes an error, the staff is re-educated in student drop and withdrawal business rules to prevent further communication lapses regarding student enrollment. Name of the contact person responsible for corrective action: Kris Ragozzino, Registrar Planned completion date for corrective action plan: Already in place.
Name of Responsible Individual: Terri Grice, University Registrar Corrective Action: Although the Registrar?s Office has experienced turnover in leadership and staff roles in recent years, the remaining staff has adapted and taken on additional duties, as needed. This past summer, the office regaine...
Name of Responsible Individual: Terri Grice, University Registrar Corrective Action: Although the Registrar?s Office has experienced turnover in leadership and staff roles in recent years, the remaining staff has adapted and taken on additional duties, as needed. This past summer, the office regained their sense of stability with the hiring of a staff member and a Registrar. The office is continuously cross-training all team members so duties are cross-checked, shared by at least two team members, and completed in a timely manner. The reports used by this office will be reviewed on a frequent basis to ensure information is being reported as it was intended. Team is also meeting with other departments to ensure information is shared consistently which will ensure accurate reporting to Clearinghouse and other agencies. Anticipated Completion Date: April 3, 2023 for five (5) audit findings/ Training will be continuous throughout the year.
Name of Responsible Individual: Brian K. Blackburn, Director of Financial Aid Corrective Action: A system error prevented scheduled Pell disbursements from taking place on the appropriate day thus creating a discrepancy in the timing of reporting. This discrepancy created the need for all disburseme...
Name of Responsible Individual: Brian K. Blackburn, Director of Financial Aid Corrective Action: A system error prevented scheduled Pell disbursements from taking place on the appropriate day thus creating a discrepancy in the timing of reporting. This discrepancy created the need for all disbursements to be verified manually and during the time needed to complete verification of the disbursement, the University was out of compliance. New reports have been created to ensure that all scheduled disbursements have disbursed within the University system and in the COD system and are accurately reported within the 15 calendar days as required. In the case of the identified student and their Direct Loan disbursement, the student's Unsubsidized loan was inadvertently disbursed with required documents missing. The University has put in to place a series of reports and measures that ensures a loan will not disburse if a student is missing required documents or is not in one of Powerfaids "Ready to Disburse" statuses. Anticipated Completion Date: March 7,2023
Name of Responsible Individual: Brian Blackburn, Director of Financial Aid Corrective Action: The University has assigned a Financial Aid Staff member to more closely monitor the NSLDS Transfer Monitoring List that comes in from NSLDS on a monthly basis and coordinate with the Registrar's Office to ...
Name of Responsible Individual: Brian Blackburn, Director of Financial Aid Corrective Action: The University has assigned a Financial Aid Staff member to more closely monitor the NSLDS Transfer Monitoring List that comes in from NSLDS on a monthly basis and coordinate with the Registrar's Office to ensure that all information is updated in a timely manner. Additionally, we have put in place a new policy that Title IV aid will not be paid until after the end of the Drop/ Add period of any given semester. Anticipated Completion Date: March 22, 2023
2022-003 FINDING: FEDERAL PERKINS LOAN COHORT DEFAULT RATE TOO HIGH Corrective Action Plan: The University?s cohort default rate significantly improves on a year-to-year basis. As indicated in the finding, the University?s cohort default rate during the Fiscal Year 2022 (for borrowers who entered...
2022-003 FINDING: FEDERAL PERKINS LOAN COHORT DEFAULT RATE TOO HIGH Corrective Action Plan: The University?s cohort default rate significantly improves on a year-to-year basis. As indicated in the finding, the University?s cohort default rate during the Fiscal Year 2022 (for borrowers who entered repayment during Fiscal Year 2021) was at 11.11%, meeting the 15% threshold. However, since the number of University borrowers who entered repayment during Fiscal Year 2021 were fewer than 30, the current cohort default rate calculation also included the University borrowers who entered into repayment and defaulted for the past three years, in accordance with federal regulations. The University will continue to closely monitor and communicate with students entering on default on a month-to-month basis, in addition to sending defaulted student loans to the Illinois State Comptroller?s Offset system. Responsible University Personnel: Villalyn Baluga, Associate Vice President for Finance; Linda Theres-Jones, Director/Chief Accountant. Anticipated completion date: Already implemented during FY 2020.
2022-002 FINDING: ENROLLMENT REPORTING Corrective Action Plan: The University reports enrollment status changes to the U.S. Department of Education?s National Student Loan Data System (NSLDS) through the National Student Clearinghouse (NSC), a third-party servicer. There is currently no mechanism...
2022-002 FINDING: ENROLLMENT REPORTING Corrective Action Plan: The University reports enrollment status changes to the U.S. Department of Education?s National Student Loan Data System (NSLDS) through the National Student Clearinghouse (NSC), a third-party servicer. There is currently no mechanism for reporting students who were administratively withdrawn after the semester (the students registered for) ended until after the next reporting cycle to the NSC. The University will work with the NSC to determine a course of action to report these exceptions to NSLDS at the earliest possible date. Responsible University Personnel: Timothy Carroll, Registrar. Anticipated completion date: Summer 2023 Term.
Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend the University review its procedures to ensure that key personnel changes are reported to the Department of Education in the required 10-day timeframe. Explanation of disagreement with audit finding: T...
Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend the University review its procedures to ensure that key personnel changes are reported to the Department of Education in the required 10-day timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CSP has made sure that more than the Financial Aid Director has the information to access the E-APP. We also put into place a secondary designated person for SAIG and other portals and process as able. Name of the contact person responsible for corrective action: Amanda McCaughan, SFA Director Planned completion date for corrective action plan: February 2023
Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Explanation of disagreement wi...
Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar's Office has been working with National Student Clearinghouse since September 22, 2022, to review findings on error reports and how to resolve the specific errors. For example, Social Security Number not matching error was instructed to send a card via email and trying to identify a safe way to provide that student information instead of through an unsecured email inbox. We are actively working on the current error report for students who flag as NSLDS errors, even though the NSC data is accurate. NSC has verified that reporting is moving to NSLDS. The Registrar's team will keep all email communication to the NSC Audit team regarding error reporting. Name of the contact person responsible for corrective action: Lynn Lundquist, Registrar Planned completion date for corrective action plan: September 2022
Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students? statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: T...
Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students? statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Registrar's Office reports enrollment data every 30 days to the National Student Clearinghouse. Registrar's Office individually updates student records to maintain compliance with the 60-day update in NSLDS. The Registrar's Office has been communicating with the National Student Clearinghouse since September of 2022 regarding timelines of NSC to NSLDS updates. NSC has confirmed that updated information has been reported in time. Registrar's Office has sought specific information regarding audit findings as reported information to NSC is within the timeline. Registrar Team has been reviewing Program and Campus Level information since September of 2022 as regulations had been newly modified. Name of the contact person responsible for corrective action: Lynn Lundquist, Registrar Planned completion date for corrective action plan: April 2023
Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4 calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in respo...
Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4 calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CSP has created and started to use a report that pulls any student with a course withdrawal to verify no withdrawals are missed for an R2T4. A 2-step review has been put place, the first review to pull the data and complete the calculation and the second review with double check and return the funds. A CSP employee in the R2T4 review process registered and is currently attending the NASFAA U R2T4 course. Additional training for all FA staff on R2T4?s will be completed by May 31st. Name of the contact person responsible for corrective action: Amanda McCaughan, SFA Director Planned completion date for corrective action plan: Additional reports are already created; additional training will be completed by May 31st
View Audit 49806 Questioned Costs: $1
Finding 43121 (2022-002)
Significant Deficiency 2022
The Director of Financial Aid will ensure that a process is created to identify students that are scheduled to graduate, withdraw, or drop below half-time in order for them all to complete exit counseling. Students will be notified at the time of withdrawal by phone, email, and a certified letter wi...
The Director of Financial Aid will ensure that a process is created to identify students that are scheduled to graduate, withdraw, or drop below half-time in order for them all to complete exit counseling. Students will be notified at the time of withdrawal by phone, email, and a certified letter with the steps to complete the exit counseling.
Finding 43120 (2022-001)
Significant Deficiency 2022
The Office of Financial Aid has created a process where they will check Common Origination Disbursement (COD) to ensure that each student has a valid entrance counseling. Each counselor will also make a notation in the Financial Aid system that the student borrower's entrance counseling has been re...
The Office of Financial Aid has created a process where they will check Common Origination Disbursement (COD) to ensure that each student has a valid entrance counseling. Each counselor will also make a notation in the Financial Aid system that the student borrower's entrance counseling has been reviewed.
Finding 43114 (2022-003)
Significant Deficiency 2022
The Controller and Compliance Officers are working together to correct the previously filed reports to update the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)...
The Controller and Compliance Officers are working together to correct the previously filed reports to update the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Completion Date: April 2023 Contact Person: Tom Corley, Controller and Director of Fiscal Operations and Carrie Stevens, Associate Vice President of Compliance
Finding 43105 (2022-002)
Significant Deficiency 2022
Student Accounts Receivable, Controller?s Office, and IT are working together to develop more real-time reporting and tracking for student account refund balances to identify student accounts with refund balances that remain undistributed more than seven days after being created to prioritize those ...
Student Accounts Receivable, Controller?s Office, and IT are working together to develop more real-time reporting and tracking for student account refund balances to identify student accounts with refund balances that remain undistributed more than seven days after being created to prioritize those accounts for refund processing. Completion Date: June 30, 2023 Contact Person: Heather Long, Director Student Accounts
Finding 43104 (2022-001)
Significant Deficiency 2022
The Registrar and the IT department are working together to ensure timely and accurate data is being transmitted on a regular schedule to the Clearinghouse as needed. When date determination exceptions occur (e.g., degrees being conferred after initial reporting or withdrawal dates being retroactive...
The Registrar and the IT department are working together to ensure timely and accurate data is being transmitted on a regular schedule to the Clearinghouse as needed. When date determination exceptions occur (e.g., degrees being conferred after initial reporting or withdrawal dates being retroactively determined for administrative purposes), the Registrar?s Office, IT, and Financial Aid will work together to determine the appropriate date adjustments needed to manually update the Clearinghouse with the correct information if needed as quickly as possible. Completion Date: June 30, 2023 Contact Person: Julie McAdoo, University Registrar
Finding 43103 (2022-002)
Significant Deficiency 2022
project Number: 21st Century - Project 553. Corrective steps: Procedures have been put in place to ensure employees are being paid in accordance with the District contracts with board approval. All extra duty contracts have been signed by the Varnum School Board. Completion date: 3-20-2023. Plan fo...
project Number: 21st Century - Project 553. Corrective steps: Procedures have been put in place to ensure employees are being paid in accordance with the District contracts with board approval. All extra duty contracts have been signed by the Varnum School Board. Completion date: 3-20-2023. Plan for monitoring adherence to the corrective action plan: The Varnum Schools Superintendent will monitor for compliance.
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