Corrective Action Plans

Finding 37782 (2022-102)

Material Weakness 2022

Maricopa County Community College District

AZ

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Cluster Name: Student Financial Assistance Cluster Assistance Listing number and name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program-Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Fede...

Cluster Name: Student Financial Assistance Cluster Assistance Listing number and name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program-Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award Year: July 1, 2021 through June 30, 2022 Federal Agency: U.S. Department of Education Compliance Requirements: Special tests and provisions Questioned Costs: Unknown Name of Contact Persons: Annette Linders, District Director of Financial Aid Operations and Compliance Anticipated Completion Date: December 31, 2023 The Maricopa County Community College District understands the need to establish and maintain effective internal controls over federal awards to provide reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms and conditions. The District further understands the need to reconcile direct loan institutional student records with direct loan disbursement records submitted to and accepted by the COD system in order to meet fiduciary responsibilities. The District will enhance internal controls and expand its current process for monitoring Student Financial Aid (SFA) offices? adherence to districtwide policies and procedures, to ensure systemwide compliance with Direct Loan program requirements. The District will enhance staff training and communication efforts; optimize District and college collaborations; provide a centralized location for completed reconciliations; and monitor each college?s submission to ensure Direct Loans are reconciled and reviewed each month on a timely basis.

View Audit 29977 Questioned Costs: $1

Finding 37781 (2022-101)

Material Weakness 2022

Maricopa County Community College District

AZ

Questioned Costs Student Financial Aid Special Tests & Provisions § 200.303

Cluster Name: Student Financial Assistance Cluster Assistance Listing number and name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program-Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Fed...

Cluster Name: Student Financial Assistance Cluster Assistance Listing number and name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program-Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award Year: July 1, 2021 through June 30, 2022 Federal Agency: U.S. Department of Education Compliance Requirements: Special tests and provisions Questioned Costs: Unknown Name of Contact Persons: Annette Linders, District Director of Financial Aid Operations and Compliance Anticipated Completion Date: December 31, 2023 The Maricopa County Community College District understands the importance of reporting accurate student enrollment statuses and all student enrollment status changes to the National Student Loan Database (NSLDS) for the Pell and Direct Loan programs within 60 days. The District will continue to monitor its Student Financial Aid (SFA) offices? adherence to Districtwide policies and procedures and enhance internal controls to ensure SFA office?s timely review, verification, and corrections to identified data prior to submitting the data to the NSLDS. District and college collaborations are being optimized; training and communications with emphasis on timeliness and completeness continue to be enhanced; and a centralized repository of enrollment reporting resources has been prepared and made available to staff.

View Audit 29977 Questioned Costs: $1

Finding 37730 (2022-001)

Significant Deficiency 2022

Rider University

NJ

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Federal Perkins Loan Program ? Assistance Listing No. 84.038 Recommendation: We recommend that the University keep MPNs for loans for the 3-year retention period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: W...

Federal Perkins Loan Program ? Assistance Listing No. 84.038 Recommendation: We recommend that the University keep MPNs for loans for the 3-year retention period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We were able to confirm that the MPN?s were inadvertently shredded due to a mold issue in the storage facility. All other MPN?s have been moved to a safer area and staff are no longer permitted to shred documents without the approval of the Associate Director (Lisa Butler). Name(s) of the contact person(s) responsible for corrective action: Lisa Butler, Associate Director Bursar Planned completion date for corrective action plan: 3/23/2023

View Audit 30445

Finding 37724 (2022-002)

Significant Deficiency 2022

Rider University

NJ

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Federal Pell Grant Program, Federal Direct Student Loans ? Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submi...

Federal Pell Grant Program, Federal Direct Student Loans ? Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Continued attendance in Clearinghouse webinars, corrected previous years? of Clearinghouse submissions that included student?s incorrect term end dates and will monitor the future warnings on the Clearinghouse Error Reports, will communicate the rejected records from NSLDS to Financial Aid and Admissions once received in an effort for all departments to work together in assisting students to confirm their SSN Name(s) of the contact person(s) responsible for corrective action: Jessica Novak, Justina Nicita & Susan Stefanick Planned completion date for corrective action plan: 3/14/2023 nd will send Financial Aid the NSLDS file for comparison.

View Audit 30445

Finding 37723 (2022-004)

Significant Deficiency 2022

Rider University

NJ

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

Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants ? Assistance Listing No. 84.063, 84.268, 84.033, 84.007 Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensu...

Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants ? Assistance Listing No. 84.063, 84.268, 84.033, 84.007 Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The R2T4 for this student will be recalculated using the correct total number of days and any and all Title IV adjustments will be made. Moving forward we will strengthen our processes so that our R2T4 calculations will be inclusive of scheduled breaks as per the FSA Handbook. Name(s) of the contact person(s) responsible for corrective action: Chris Corrato, Assistant Director & Amanda Young, Associate Director Planned completion date for corrective action plan: 3/23/2023

View Audit 30445 Questioned Costs: $1

Finding 37722 (2022-005)

Significant Deficiency 2022

Rider University

NJ

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

Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants ? Assistance Listing No. 84.063, 84.268, 84.033, 84.007 Recommendation: We recommend the University implements procedures to ensure that Title IV funds that are ...

Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants ? Assistance Listing No. 84.063, 84.268, 84.033, 84.007 Recommendation: We recommend the University implements procedures to ensure that Title IV funds that are to be returned are returned in the proper order. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We currently ensure that all R2T4 calculations are done in the appropriate order as stated in the FSA Handbook by the Department of Education. Moving forward we will strengthen our procedures so that the returned funds are processed to COD in the proper order. Name(s) of the contact person(s) responsible for corrective action: Chris Corrato, Assistant Director, Amanda Young, Associate Director and Stephanie Falsetti, Assistant Director Planned completion date for corrective action plan: 3/23/2023

View Audit 30445

Finding 37710 (2022-001)

None 2022

Universidad Central De Bayamon INC

PR

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking

Finding No. 2022?001 ? Special Tests and Provisions ? Return of Title IV Funds Condition found. The return of Title IV funds as calculated by the University was performed after the required 45 days, in the following case: Student Id. No. Determination date Refund date 92710 6/24/2022 8/24/2022 Manag...

Finding No. 2022?001 ? Special Tests and Provisions ? Return of Title IV Funds Condition found. The return of Title IV funds as calculated by the University was performed after the required 45 days, in the following case: Student Id. No. Determination date Refund date 92710 6/24/2022 8/24/2022 Management Response The University agrees with the finding. Corrective Action Plan The University affirms its understanding of its obligation to submit the return of Title IV funds due to a total withdrawal to the Department of Education no later than 45 days after the determination date, the date that the school became aware that the student withdrew. In this case, the disbursement of Title IV funds was posted at the same date and time the R2T4 was processed, and one process blocked the other. To avoid this issue, officials must be aware that process that involve return of funds should be processed on different days than the disbursement of Title IV funds are processed. Name of the Contact Person Responsible for Corrective Action Elaine Nu?ez, Financial Aid Office Director Anticipated Completion Date During fiscal year 2022-2023

View Audit 29720

Finding 37646 (2022-002)

Significant Deficiency 2022

Cornell College

IA

Student Financial Aid Reporting Significant Deficiency

2022-002 SCHER1 ? Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 Recommendation: We recommend that the College 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 ...

2022-002 SCHER1 ? Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 Recommendation: We recommend that the College 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 College will continue to monitor errors within SCHEER 1 to ensure they are corrected within 10 days. Name(s) of the contact person(s) responsible for corrective action: Pam Perry Planned completion date for corrective action plan: The process was implemented in July 2021.

View Audit 36236

Finding 37643 (2022-001)

Material Weakness 2022

South Suburban College - Community College District #510

IL

Student Financial Aid Reporting

SECTION III ? FEDERAL AWARD FINDINGS AND QUESTIONS COSTS FINDING 2022-001 ? CONTROLS AND NONCOMPLIANCE OVER REPORTING Management?s Response The College accepts this finding and will add additional steps to reinforce established policies and procedures regarding timely submission of the COD inform...

SECTION III ? FEDERAL AWARD FINDINGS AND QUESTIONS COSTS FINDING 2022-001 ? CONTROLS AND NONCOMPLIANCE OVER REPORTING Management?s Response The College accepts this finding and will add additional steps to reinforce established policies and procedures regarding timely submission of the COD information. Plan The College?s Student Financial Aid department has developed additional steps to reinforce established policies and procedures regarding timely submission of the COD information. These steps are outlined below. Every Friday the Director (Manager in absence of Director) runs the FATP report and provides the report to the Manager. The Manager (Coordinator if Manager runs FATP) reviews sample of report and confirms via email to Director and Manager (if appropriate). The Manager (Coordinator in absence of Manager) sends sample the Business Office Every Tuesday the Business Office reviews sample in ASAI (Student Account History). If correct, the Business Office solicits final-signoff from Director of Financial Aid (Manager in absence of Director). The Director of Financial Aid (Manager in absence of Director) reviews and signs-off on the document and returns to the Business Office. Upon receipt of sign-off Business Office transmits funds to COD and prepares drawdown request. Anticipated Date of Completion 1/1/2023 Name of Contact Person Avianca Taylor

View Audit 34723

Finding 37642 (2022-002)

Material Weakness 2022

South Suburban College - Community College District #510

IL

Questioned Costs Student Financial Aid Eligibility

SECTION III ? FEDERAL AWARD FINDINGS AND QUESTIONS COSTS FINDING 2022-002 ? CONTROLS AND NONCOMPLIANCE OVER ELIGIBILITY AND DISBURSEMENT Management?s Response The College accepts this finding and will continue to undergo updates in procedures regarding documentation retention. Plan SSC Student ...

SECTION III ? FEDERAL AWARD FINDINGS AND QUESTIONS COSTS FINDING 2022-002 ? CONTROLS AND NONCOMPLIANCE OVER ELIGIBILITY AND DISBURSEMENT Management?s Response The College accepts this finding and will continue to undergo updates in procedures regarding documentation retention. Plan SSC Student Financial Aid is in the process of developing an electronic document retention system. In the meantime, all documents are being retained in student files via hardcopy format under the supervision of the Manager. Each Friday the Manager (Coordinator in the absence of Manager) and Director audit files of students receiving FSEOG to verify document retention. Additionally, the College is implementing a Colleague rule to prevent disbursement of FSEOG to any student who does not have a $0 EFC. This is in addition to the existing rule that requires a student to be receiving a Federal Pell Grant in order to have a Federal SEOG disbursement paid to their College account. Anticipated Date of Completion 1/1/2023 Name of Contact Person Avianca Taylor

View Audit 34723 Questioned Costs: $1

Finding 37640 (2022-002)

Significant Deficiency 2022

Northcentral University

CA

Student Financial Aid Reporting Subrecipient Monitoring

FINDING 2022-002 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Recommendation: We recommend that the University develop additional procedures to monitor the accuracy of information provided by its third-party servicer on behalf of the University t...

FINDING 2022-002 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Recommendation: We recommend that the University develop additional procedures to monitor the accuracy of information provided by its third-party servicer on behalf of the University to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to correct information directly within NSLDS at any time. Views of Responsible Officials and Planned Corrective Actions ? Management agrees with the importance of ensuring timely and accurate NSLDS reporting in accordance with 34 CFR section 685.309(b)(2)(i)). The NCU Quality Assurance, under Brandy Baker, team now reviews enrollment reporting on a regular basis to confirm the reporting process is consistent with the Title IV regulation. Starting in January 2023, Quality Assurance team leads investigations while partnering with our Financial Aid Director, Kimberly Quinn, and our Registrar team, under Chris Alvarado, to determine the cause of the inaccurate reporting for quality assurance review findings and will work with the appropriate departments and teams to ensure that any required corrections to process, reporting, reporting code or systems is rectified. Management agrees with the importance of communicating with the Department of Education when an enrolled student ceases to be enrolled at least half-time.

View Audit 31839

Finding 37639 (2022-001)

Significant Deficiency 2022

Northcentral University

CA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Significant Deficiency in Internal Control Recommendation ? We recommend NCU revise their system queries to capture all withdrawn students and implement a process by which the queries are tested annually. We also recommend NCU im...

FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Significant Deficiency in Internal Control Recommendation ? We recommend NCU revise their system queries to capture all withdrawn students and implement a process by which the queries are tested annually. We also recommend NCU implement a process in which there is a final review of the Title IV return after the fact for all students to ensure all aspects are correct and timely. Views of Responsible Officials and Planned Corrective Actions ? Management agrees with the importance of ensuring that the return of Title IV funds (R2T4) is performed both timely and accurately. In November 2022, the University instituted a new workflow process that is easily tracked and reported, allowing our Processing, under Kimberly Quinn, and Quality Assurance, under Brandy Baker, teams to monitor and control the R2T4 process more effectively. In addition, the Quality Assurance team at NCU is now performing regular and periodic file reviews to ensure file accuracy. The Quality Assurance process includes a review of both an assessment of the accuracy of our calculations and that all required R2T4s are complete. These new internal controls ensure we process R2T4 in accordance with 34 CFR section 668.22 (2)(i) in the required timeframe. We anticipate the changes mentioned above will remediate this finding.

View Audit 31839

Finding 37590 (2022-002)

None 2022

East Texas Baptist University

TX

Questioned Costs Student Financial Aid Eligibility

R2T4 Planned Corrective Action: ETBU Registrars office is now informing the Financial aid office of any student who withdrawals or that is reported as not attending in courses from the second FLEX terms. Financial aid is awarded based on total payment period enrollment and any notification of chan...

R2T4 Planned Corrective Action: ETBU Registrars office is now informing the Financial aid office of any student who withdrawals or that is reported as not attending in courses from the second FLEX terms. Financial aid is awarded based on total payment period enrollment and any notification of change in enrollment will result in a review and recalculation of aid eligibility if necessary. Reports were revised to reflect changes in enrollment after primary term census. Person Responsible for Corrective Action: Troy White, Registrar and Linda Slawson, Director of Financial aid. Anticipated Date of Completion: Already implemented.

View Audit 35821 Questioned Costs: $1

Finding 37578 (2022-002)

Significant Deficiency 2022

Warner University, Inc.

CO

Student Financial Aid Eligibility Significant Deficiency

Finding Number: 2022-002 Planned Corrective Action: Cost of attendance budgets will be established prior to any financial aid awarding. Person Responsible for Corrective Action Plan: Director of Financial Aid Compliance, Elease Cox Anticipated Date of Completion: Already implemented, Fall 2022

View Audit 35197

Finding 37577 (2022-001)

Material Weakness 2022

Warner University, Inc.

CO

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

Finding Number: 2022-001 Planned Corrective Action: Multiple staff will verify the dates used in the Common Origination and Disbursement's (COD) R2T4 calculator. Additionally, procedures have been updated to require the proper sequence that departments engage in the R2T4 process and mini-sessions ar...

Finding Number: 2022-001 Planned Corrective Action: Multiple staff will verify the dates used in the Common Origination and Disbursement's (COD) R2T4 calculator. Additionally, procedures have been updated to require the proper sequence that departments engage in the R2T4 process and mini-sessions are now interpreted as modular courses. Person Responsible for Corrective Action Plan: Director of Financial Aid Compliance, Elease Cox Anticipated Date of Completion: Already implemented, Fall 2022

View Audit 35197 Questioned Costs: $1

Finding 37528 (2022-001)

Significant Deficiency 2022

North Central Missouri College

MO

Student Financial Aid Special Tests & Provisions Reporting

U.S. DEPARTMENT OF EDUCATION North Central Missouri College respectfully submits the following corrective action plan for the year ended June 30, 2022. Contact information for the individual responsible for the corrective action: Mr. Tyson Otto, Vice President of Business & Finance North Central Mis...

U.S. DEPARTMENT OF EDUCATION North Central Missouri College respectfully submits the following corrective action plan for the year ended June 30, 2022. Contact information for the individual responsible for the corrective action: Mr. Tyson Otto, Vice President of Business & Finance North Central Missouri College 1601 Main Street Trenton, MO 64683 (660) 359-3948 Independent public accounting firm: KPM CPAs, PC, 1145 E Republic Rd, Springfield, Missouri 65804 Audit Period: Year Ended June 30, 2022 The finding from the June 30, 2022, audit of the financial statements is below. The finding is numbered with the number assigned in the schedule. FINDING - MAJOR FEDERAL AWARD PROGRAM AUDIT 2022-001 Special Test and Provisions - Return of Title IV Funds Recommendation: The College implement procedures in order to strictly comply with the requirements of 34 CFR 668.173 as it relates to the return of Title IV funds. Corrective Action Taken: To ensure the NCMC Financial Aid Office complies with the requirements of 34 CFR 668.173 as it relates to the return of Title IV funds, an additional weekly report was implemented to identify all withdraws and confirm an R2T4 calculation was performed (if required). Anticipated Completion Date: Fall semester 2022 and ongoing.

View Audit 31692

Finding 37512 (2022-007)

Significant Deficiency 2022

County of Delaware

PA

Student Financial Aid Eligibility Internal Control / Segregation of Duties

Recommendation: The County Children and Youth Services department should implement a file checklist to ensure copies of all Adoption Assistance recipients are complete. Program directors should review the file checklist and compare to the file when determination of eligibility is complete. Checklist...

Recommendation: The County Children and Youth Services department should implement a file checklist to ensure copies of all Adoption Assistance recipients are complete. Program directors should review the file checklist and compare to the file when determination of eligibility is complete. Checklists should be signed and dated to ensure the approvals are completed. Staff should be trained on eligibility file record requirements and use of checklists to ensure consistent application of the policies. Action Taken: Starting in February 2023, the County Human Services Department hired a consultant that is completing an internal reconciliation of and review of all 2022-2023 records. Adoption file requirements and checklists have been implemented by the consultant to ensure consistent and complete files. The County CYS office will implement the checklists and policies of the consultant in file management. In addition, action is being taken to digitize all records for active adoption assistance recipients to ensure access is maintained and changes to Adoption Assistance files are kept updated. Responsible Individual for Corrective Action: Angelique Hiers, County of Delaware Department of Human Services Director Completion Date: December 31, 2023

View Audit 29504

Finding 37504 (2022-005)

Material Weakness 2022

County of Delaware

PA

Student Financial Aid

Recommendation: The County Domestic Relations department will communicate the requirements regarding the required time frame for conversion of applications/petitions to a case file to the department staff. Action Taken: This finding occurred as a result of IV-A case referrals from the County Assista...

Recommendation: The County Domestic Relations department will communicate the requirements regarding the required time frame for conversion of applications/petitions to a case file to the department staff. Action Taken: This finding occurred as a result of IV-A case referrals from the County Assistance Office. In order to comply with the directive it is necessary that we receive verifiable and sufficient information from the CAO. We did not receive all information necessary from the CAO to comply in these instances. It would have been inappropriate to proceed. Domestic Relations Department will provide semi-annual training to the Intake Unit staff in Case Initiation, record retention, time frame for conversion of applications/petitions to case files and file documentation beginning in November 2023. Responsible Individual for Corrective Action: Patricia Coacher, County of Delaware Domestic Relations Director Completion Date: December 31, 2023

View Audit 29504

Finding 37467 (2022-001)

None 2022

Pace University

NY

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

The Financial Aid directors have been on a path to automate a number of processes, including the Notification of Federal Loan Disbursement. To assist in streamlining our processes and improving the overall student experience, the University has engaged the services of an outside consultant, CampusWo...

The Financial Aid directors have been on a path to automate a number of processes, including the Notification of Federal Loan Disbursement. To assist in streamlining our processes and improving the overall student experience, the University has engaged the services of an outside consultant, CampusWorks, on a two-year contract, which commenced on October 18, 2022, to work with relevant Pace personnel on Enterprise Systems modernization. Although this delay in notification is for an isolated time period, the Notification of Disbursement process has been automated as of February 23, 2023, and notifications will be released systematically on a regular schedule, in line with federal guidelines.

View Audit 28416

Finding 37461 (2022-001)

Significant Deficiency 2022

Massachusetts Maritime Academy

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans AL #?s: 84.268 Award year: 2022 Corrective Action Plan: A background process that was automated to send loan information to COD on a twice weekly basis stopped run...

Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans AL #?s: 84.268 Award year: 2022 Corrective Action Plan: A background process that was automated to send loan information to COD on a twice weekly basis stopped running and had not detected it in a timely manner. The issue with the background process has been resolved and will be monitored to make sure it continues to run on a consistent basis to ensure timely communication within regulation. Timeline for Implementation of Corrective Action Plan: This has already been implemented Contact Person Catherine Kedski, Director of Student Financial Services

View Audit 29045

Finding 37289 (2022-002)

Significant Deficiency 2022

State of Texas C/o Comptroller of Public Accounts

TX

Questioned Costs Eligibility Internal Control / Segregation of Duties § 200.303

EA Application/Determination Corrective action plan: DFPS will ensure that INV/AR staff receive ongoing communication/training regarding EA and how to correctly document and record income within the IMPACT. DFPS will update the current EA policy and publishing a new resource guide for staff. DFPS ...

EA Application/Determination Corrective action plan: DFPS will ensure that INV/AR staff receive ongoing communication/training regarding EA and how to correctly document and record income within the IMPACT. DFPS will update the current EA policy and publishing a new resource guide for staff. DFPS staff will be provided training, tip sheets and ongoing support regarding the new policy and resource guide. The policy will be published by April 1, 2023. DFPS will continue to strengthen our internal quality assurance review of cases eligible for EA to ensure that INV/AR staff are complying with federal guidelines and internal policies. DFPS has submitted an IT ticket request to resolve the condition for the participant that had the incorrect income range of $0-$10,000 selected to the correct income range of $20,550 to $40,549 to align with the investigation report. The participant remains eligible for assistance regardless as the family unit makes less than $63,000. CPI will initiate a request for an IT project to conduct analysis of any limitations with verifying Emergency Assistance eligibility in the IMPACT system regarding why two of the three EA statements now show not answered. DFPS staff will be researching the issue to determine next steps by 2nd quarter FY 2024. Implementation date(s): Ongoing communication ? will vary, first communication by April 1, 2023; IMPACT research January 31, 2024. Responsible persons: Jerome Green PEAF Corrective action plan: DFPS uses an established recoupment process to address overpayments. A Kinship Development Worker writes a letter to the kinship caregiver regarding the overpayment and details the steps needed to return funds. This letter is also sent to accounting for follow up. DFPS maintains a proactive approach to strengthening/enhancing IMPACT limitations to ensure accurate data is maintained for accurate payments/disbursements through continuous program improvement. Implementation date(s): On January 13, 2023 ? staff initiated the above described recoupment process to recoup the second payment for the subject children. Responsible persons: Debbie Bouldin

View Audit 28519 Questioned Costs: $1

Finding 37260 (2022-001)

Significant Deficiency 2022

Vanguard University of Southern California and Affiliates

CA

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions

Management's Corrective Action Plan - Finding 2022-001: Special Tests: Return of Title IV Funds - In our 2021-22 audit it was identified that a Return of Title IV funding (R2T4) occurred outside of the required 45 day window. During the 2021-22 year the Financial Aid Office was continually working o...

Management's Corrective Action Plan - Finding 2022-001: Special Tests: Return of Title IV Funds - In our 2021-22 audit it was identified that a Return of Title IV funding (R2T4) occurred outside of the required 45 day window. During the 2021-22 year the Financial Aid Office was continually working on finding the most accurate ways to ensure that all withdrawals were identified and reviewed for R2T4 processing within the necessary time frames. We were using multiple reports that were created and delivered from various departments to screen all enrollment status changes, however, these reports were not capturing all necessary information which caused us to not identify the student in question until we were outside of the 45 day window to return funds. We have since worked to create a new report that captures all enrollment changes for the semester within one report. The new report is now delivered on a weekly basis for review to ensure that all required R2T4 deadlines are met. - Contact Person: Chris, Preszler, Director of Financial Aid - Anticipated Completion Date: November 30, 2022.

View Audit 80777

Finding 37232 (2022-003)

Significant Deficiency 2022

Bethany College

KS

Special Tests & Provisions Student Financial Aid Reporting

Corrective Action Plan 2022-003: The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to report disbursement dates to COD. Completion Date: January 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services

View Audit 30545

Finding 37229 (2022-004)

Significant Deficiency 2022

Bethany College

KS

Questioned Costs Special Tests & Provisions Student Financial Aid

Corrective Action Plan 2022-004: The College concurs with the finding and has provided corrective action through adding additional review of the calculation of institutionally scheduled breaks and total days used in the R2T4 calculations. Completion Date: May 2022 Contact Person: Christoffer Larse...

Corrective Action Plan 2022-004: The College concurs with the finding and has provided corrective action through adding additional review of the calculation of institutionally scheduled breaks and total days used in the R2T4 calculations. Completion Date: May 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services

View Audit 30545 Questioned Costs: $1

Finding 37096 (2022-001)

None 2022

Mid Michigan College

MI

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

CORRECTIVE ACTION PLAN The compliance audit identified one finding, which is described in the Schedule of Findings and Questioned Costs. We evaluated this matter, as described below, and have outlined our corrective actions as a result. 2022-001 - Timeliness of Student Status Changes Background G...

CORRECTIVE ACTION PLAN The compliance audit identified one finding, which is described in the Schedule of Findings and Questioned Costs. We evaluated this matter, as described below, and have outlined our corrective actions as a result. 2022-001 - Timeliness of Student Status Changes Background Gabrielle Coles was found to be reported to NSLDS for enrollment status change 9 days late, on the 69th day. This student officially withdrew from the Fall 2021 semester on November 30, 2021. At the time of the fall withdrawal, the student was also registered for winter term at half time. The original setup of the Colleague system caused the incorrect enrollment status to be reported for the student (as it was not considering the use of the unofficial withdrawal date in the Clearinghouse report file). However, we do have measures in place to review our withdrawn students one by one out in NSLDS to ensure we are compliant. When it was found by the Financial Aid Specialist that an error was reported to NSLDS, the responsible party -the former Registrar- was notified on two separate occasions to have the status updated; both notifications happened prior to the 60-day mark. Despite the notifications, the error was not updated until the 69th day. Issue The Colleague system did not correctly pull the withdrawal status or correct date. However, the issue was found well before the 60-day mark by the Financial Aid Specialist who reviews each withdrawn student in NSLDS biweekly. The Specialist did notify the responsible party of the error (twice). Due to human error (as we believe the former Registrar did not notice the fall withdrawal but instead only saw the half time winter registration), the issue was not resolved in time. This individual no longer works at the college. Subsequent to this issue, IT was engaged to look further into the Colleague report to identify the root cause of why some students were being reported with the wrong dates. After much research, we changed how the report was pulling withdrawn students and their withdrawal date. This change will also prevent issues from occurring in the future. Resolution With the corrective action plan put in place of both the Colleague system considering the unofficial date of withdrawal and the Financial Aid Specialist notifying the responsible party of enrollment status changes that are incorrect at NSLDS, we are confident that the enrollment reporting requirements should now be met. Responsible Party Director of Financial Aid ? Sarah Kasabian-Larson Date of Planned Corrective Action Effective immediately. March 2nd, 2022 Management Assessment We concur with the audit assessment regarding this matter.

View Audit 33915

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