Corrective Action Plans

Finding 37095 (2022-001)

Material Weakness 2022

NY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

We concur with this finding. The finding noted is a result of isolated instances of failure to adhere to established institutional procedures. Henceforth, the Registrar?s Office will update students? status changes after receipt from the Academic Affairs Office. Changes will be reported to the Natio...

We concur with this finding. The finding noted is a result of isolated instances of failure to adhere to established institutional procedures. Henceforth, the Registrar?s Office will update students? status changes after receipt from the Academic Affairs Office. Changes will be reported to the National Student Loan Clearinghouse within the 60-day submission period. This process will go into effect immediately.

View Audit 34346

Finding 37089 (2022-001)

None 2022

County of Cumberland, Pennsylvania

PA

Student Financial Aid Reporting

Finding 2022-001: Reporting Finding Title: Reporting Timeliness Anticipated Completion Date: Already Implemented Name of Agency Responsible for carrying out the corrective action plan: Children and Youth Person in the agency (name & title): Lisa A. Reider, Financial Manager Cumberland County Child...

Finding 2022-001: Reporting Finding Title: Reporting Timeliness Anticipated Completion Date: Already Implemented Name of Agency Responsible for carrying out the corrective action plan: Children and Youth Person in the agency (name & title): Lisa A. Reider, Financial Manager Cumberland County Children and Youth Services continues to work with our providers for timelier invoice submissions. One of the controls we have in place is for the Administrative Technician to request any outstanding invoices each month when the Financial Manager is completing the expense accrual for the monthly County Close process. Even if we obtain more timely submission of invoices from our providers it will not remediate the issue of timeliness for submitting the Act 148 reports within 45 days of the end of a quarter. There can be various other reasons for late Act 148 report submission beyond untimely provider invoices. Factors such as provider contracts and determining a child?s eligibility for Title IV-E funding can also play a significant role in the submission process. It is essential to confirm that all aspects of the administrative and eligibility requirements are met to avoid errors and ensure accurate invoicing to the federal government. Untimely Act 148 reporting is a statewide issue. While timeliness is imperative for meeting deadlines and compliance, in most instances the reporting schedule requires more than 45 days to work through all the administrative and eligibility requirements.

View Audit 30661

Finding 37043 (2022-001)

Significant Deficiency 2022

University of Redlands

CA

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

CORRECTIVE ACTION PLAN Audit Finding 2022-001 Special Tests and Provisions Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Data Transmission Errors - University of Redlands data submitted to its third-party provider, the National Student Clearinghouse, will be audite...

CORRECTIVE ACTION PLAN Audit Finding 2022-001 Special Tests and Provisions Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Data Transmission Errors - University of Redlands data submitted to its third-party provider, the National Student Clearinghouse, will be audited via reports generated from directly from the NSLDS. The University Registrar will request access to the respective federal sites in order to run said reports. Delayed Degree Conferral - The Academic Catalog currently lists 4 conferral or graduation dates: Commencement, May 31, August 31, and December 31. This language will be changed to confer degrees the date of the last semester enrolled. - Degrees awarded outside of the typical reporting cycle will be reported manually through the National Student Clearinghouse and not held until the next degree reporting cycle. Contact Person Responsible for Corrective Action: Eric Maczka, University Registrar; eric_maczka@redlands.edu, 909-748-8333 Anticipated Completion Date: December 31, 2022

View Audit 28031

Finding 37010 (2022-003)

Significant Deficiency 2022

United Theological Seminary of the Twin Cities

MN

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

Finding: Special Tests and Provisions: Borrower Transmission Data The Seminary must report all loan disbursements and submit required records to the Direct Loan Servicing System (?DLSS?) via the Common Origination and Disbursement (?COD?) within 30 days of disbursement. Disbursement dates and amoun...

Finding: Special Tests and Provisions: Borrower Transmission Data The Seminary must report all loan disbursements and submit required records to the Direct Loan Servicing System (?DLSS?) via the Common Origination and Disbursement (?COD?) within 30 days of disbursement. Disbursement dates and amounts in the DLSS must be supported by the Seminary?s records. Out of thirteen students selected for testing, one student had a date reported to COD outside of the required timeframe. Views of Responsible Officials and Planned Corrective Actions: Management is in agreement with this finding. Develop/enhance disbursement rules, policies and procedures. Submit/adjust COD disbursement records timely. Immediately update COD estimated disbursement dates when aid is posted to the student's account. Responsible Official: Tafe Lindsey Completion Date: Ongoing

View Audit 36276

Finding 37009 (2022-002)

Material Weakness 2022

United Theological Seminary of the Twin Cities

MN

Reporting Special Tests & Provisions Student Financial Aid

Finding: Special Tests and Provisions: Enrollment Reporting Changes in enrollment to less than half time, graduated or withdrawn must be reported to the National Student Loan Data System within 30 days. However, if a roster file is expected within 60 days of the status change, a school may provide t...

Finding: Special Tests and Provisions: Enrollment Reporting Changes in enrollment to less than half time, graduated or withdrawn must be reported to the National Student Loan Data System within 30 days. However, if a roster file is expected within 60 days of the status change, a school may provide the data on that roster file. Of the three students within the sample of students tested that had status changes, all were reported to NSLDS outside of the required timeline, and two were reported to NSLDS inaccurately subsequent to the 2021-2022 fiscal year. Views of Responsible Officials and Planned Corrective Actions: Management is in agreement with this finding. Update the Student Information System timely; have a process in place with specific people responsible for updating and submitting the roster timely; train staff; create and follow policies and procedures to ensure there are no delays in reporting a change in status. Management will implement a reporting mechanism to identify and a process to address withdrawals as determined whereby updates will be submitted to the NSLDS Responsible Official: Tafe Lindsey Completion Date: Ongoing

View Audit 36276

Finding 36980 (2022-003)

None 2022

Queens University of Charlotte

NC

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

Admission data for one student was misclassified as an entering freshman when student was a transfer student. We have identified the source of the issue and taken the appropriate steps to correct on both the Admissions and Financial Aid sides going forward.

View Audit 25157

Finding 36976 (2022-004)

None 2022

Queens University of Charlotte

NC

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

The Registrar?s Office will add an additional staff person to assist in reviewing and updating any error files that are received through the Clearinghouse site.

View Audit 25157

Finding 36975 (2022-001)

None 2022

Queens University of Charlotte

NC

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Two students were not included in the conferral file that was transmitted to the National Student Clearinghouse. For 3 of 27 Campus-Level Records sampled, the University did not report the student?s change in status in a timely notification to the NSLDS website. For 3 of 27 Program-Level Records sam...

Two students were not included in the conferral file that was transmitted to the National Student Clearinghouse. For 3 of 27 Campus-Level Records sampled, the University did not report the student?s change in status in a timely notification to the NSLDS website. For 3 of 27 Program-Level Records sampled, the University did not report the student?s change in status in a timely notification to the NSLDS website. For 5 of 27 Program-Level Records sampled, the University did not accurately report all significant data elements in a timely notification to the NSLDS website. While NSC records were reviewed, these items were not caught. Moving forward, two staff members will review each record to ensure that the graduated status is reported correctly. We will work with Student Financial Services to determine if there is a NSLDS report that can be pulled and reviewed after each conferral cycle. Program level data was reported to the NSC. We will work with the NSC to determine why all records aren?t being reported to the NSLDS.

View Audit 25157

Finding 36934 (2022-001)

Significant Deficiency 2022

Edgewood College, Inc.

WI

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

2022-001 Agency: U.S. Department of Education Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268, and 84.379 Program: Student Financial Aid Program Cluster Condition: Management?s review of the Return of Title IV (R2T4) calculation did not detect errors on the dates used in the calcul...

2022-001 Agency: U.S. Department of Education Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268, and 84.379 Program: Student Financial Aid Program Cluster Condition: Management?s review of the Return of Title IV (R2T4) calculation did not detect errors on the dates used in the calculation. We identified the federal aid refunds for students in the Fall 2021 semester were not calculated correctly resulting the incorrect amount being refunded. Criteria: The College is responsible for designing, implementing and maintaining internal control over compliance for special tests and provisions and for accurately calculating the R2T4 refund. When a recipient of Title IV grant or loan assistance withdrawals from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV program as soon as possible but no later than 45 days after the withdrawal date. Questioned costs: The amount of questioned costs was $1,062. Context: We tested three (3) students out of eleven (11) students that received a refund. Seven (7) of the eleven (11) student refunds occurred in the fall semester. Cause: The College?s internal control over compliance did not detect and correct the errors. Management has indicated the R2T4 calculation was not correctly calculated as the dates entered into the software were outdated due to the semester dates changing. Effect: The College processed R2T4?s incorrectly and returned the incorrect amount of funds and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review their processes and controls in place to ensure appropriate refunds are made relating to Title IV grant funding. Corrective Action Plan: The Associate Director will request the academic year calendar directly from Academic Dean?s office prior to setting up R2T4 parameters in Department of Education?s Common Origination and Disbursement (COD) system each semester. After student financial aid personnel enter the semester dates in COD, the Director or Associate Director will verify the dates entered agree to the academic calendar. Responsible Person: Katie Sprunger, Associate Director Implementation Date: Immediate

View Audit 35014

Finding 36933 (2022-001)

None 2022

The Master's University & Seminary and Subsidiary

CA

Student Financial Aid

Pell Award Policy Planned Corrective Action: To comply with the 150% Pell Rule from the GEN-17-06 Dear Colleague Letter, TMU will proceed as follows. TMU will communicate with all Pell eligible students regarding summer term eligibility. TMU will conduct audit units 2 weeks before and 2 week aft...

Pell Award Policy Planned Corrective Action: To comply with the 150% Pell Rule from the GEN-17-06 Dear Colleague Letter, TMU will proceed as follows. TMU will communicate with all Pell eligible students regarding summer term eligibility. TMU will conduct audit units 2 weeks before and 2 week after the start of summer session 1 courses and again 2 week prior and 2 weeks after start of summer session 2 courses to confirm enrollment of Pell eligible students. TMU will calculate Pell eligibility based on this information and add the additional Pell to the summer POE in the financial aid system. These steps have been added to the Financial Aid Policy and Procedure manual beginning with the 2022-2023 school year. Person Responsible for Corrective Action Plan: Kenneth Piester, Director of Financial Aid Anticipated Date of Completion: 10/06/2022

View Audit 33734

Finding 36828 (2022-004)

Material Weakness 2022

New Jersey City University

NJ

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

The University agrees with the finding and to ensure compliance with the federal requirements that disbursement data be reported within the 15-calendar window, the Financial Aid Director is in the process of developing a new Policy that will address the review of rejected or denied Pell Disbursement...

The University agrees with the finding and to ensure compliance with the federal requirements that disbursement data be reported within the 15-calendar window, the Financial Aid Director is in the process of developing a new Policy that will address the review of rejected or denied Pell Disbursement. Any Pell Award that is disbursed but rejected or denied on COD will be cancelled off student accounts while the Financial Aid Office resolves the reason why a Pell Grant disbursement was rejected or denied. Some situations cannot be resolved within the 15-day window. It is therefore prudent for the University to remove the Pell disbursement and resolve the issue before re-disbursing the award. The new Policy will also include a pre-disbursement authorization process to confirm that the disbursement once requested will be accepted on COD, therefore reducing the risk of the University disbursing a Pell Award that will be rejected on COD. The University has also contracted with a PeopleSoft consultant to address the manual processes and develop a more automated business process.

View Audit 35370

Finding 36719 (2022-017)

Material Weakness 2022

Government of the District of Columbia

DC

Questioned Costs Student Financial Aid Eligibility § 200.303

CFSA concurs with the findings as stated. For bullet point #1 of the findings noted: This appears to be a data entry error that occurred during the eligibility team?s preparation for the single audit. The room & board costs that occurred during the erroneous ?Eligible Not Reimbursable? period on t...

CFSA concurs with the findings as stated. For bullet point #1 of the findings noted: This appears to be a data entry error that occurred during the eligibility team?s preparation for the single audit. The room & board costs that occurred during the erroneous ?Eligible Not Reimbursable? period on the redetermination form were claimed to title IV-E in real time during CFSA?s quarterly claiming process. The Supervisory Eligibility Specialist has already begun a 10% quarterly quality review process of all eligibility determinations. For bullet point #2 of the findings noted: The youths in question were enrolled in high school at the start of the school year (and reflected as such in the FACES system) but were actually chronically truant. CFSA?s Business Services Administration and the Office of Youth Empowerment have implemented a joint quarterly review of the educational/employment/incapacity status of 18-to-21-year-old youth who are IV-E eligible to ensure that they meet federal requirements to support IV-E claims on their behalf. For bullet point #3 of the findings noted: The issues with background checks pertained to ?other adults residing in the home? who were not the licensed foster parents. The corrective action going forward is to produce source documentation during the audit that identifies the household composition of the foster family home so that the auditors have a clear picture of those who are adults and therefore require evidence that background checks were completed satisfactorily for IV-E eligibility purposes. CFSA will include the sections of the applications/re-applications for foster family home licensure, as appropriate, into the digital catalogue of readily available licensure documentation available for audit retrieval. These documents corroborate household composition for the purpose of identifying who, within the household, requires background checks. See Corrective Action Plan for chart/table

View Audit 31369 Questioned Costs: $1

Finding 36718 (2022-016)

Significant Deficiency 2022

Government of the District of Columbia

DC

Allowable Costs / Cost Principles Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

CFSA concurs with the finding as stated. In the three (3) instances of overtime payments in the sample, the employees in question were designated ?on-call? staff during non-business hours. In the event of emergency situations involving child protection or child placement, the ?on-call? staff are r...

CFSA concurs with the finding as stated. In the three (3) instances of overtime payments in the sample, the employees in question were designated ?on-call? staff during non-business hours. In the event of emergency situations involving child protection or child placement, the ?on-call? staff are required to report to work to assist with resolution to the child-based emergency. Their overtime is essentially pre-approved by their management team. CFSA will orient staff to a uniform process to record and account for staff-specific, day-specific, and duration-specific instances of overtime. CFSA will train and monitor usage, and full implementation will occur by September 30, 2023. See Corrective Action Plan for chart/table

View Audit 31369

Finding 36711 (2022-014)

Material Weakness 2022

Government of the District of Columbia

DC

Student Financial Aid Eligibility HUD Housing Programs § 200.303

DOEE agrees with the conditions and recommendations of this finding. DOEE proposes to strengthen its controls in the following manner: ? DOEE?s third party database developer updated the code in fiscal year 2022 to prevent occurrences of incorrect benefit amounts generated due to an error in ident...

DOEE agrees with the conditions and recommendations of this finding. DOEE proposes to strengthen its controls in the following manner: ? DOEE?s third party database developer updated the code in fiscal year 2022 to prevent occurrences of incorrect benefit amounts generated due to an error in identifying correctly inputted income amounts. The overall operations and maintenance of the eligibility systems ensure the code remains updated with accurate information. ? In fiscal year 2022, DOEE implemented a quality assurance (Q/A) check of benefit payments to identify database errors and duplicate benefits before submitting benefit payments to Utility vendors. DOEE continues this process today to ensure that database errors are identified and addressed in a timely manner. DOEE?s database developer will create and modify the second review report that is exportable to formats that can be read and understood and inclusive of all signed second application reviews. ? DOEE will conduct, and require participation by staff in, quarterly system demonstration and refresher trainings in order to strengthen existing policies and procedures to ensure the review of applications and household size are correctly recorded into the system. See Corrective Action Plan for chart/table

View Audit 31369

Finding 36709 (2022-013)

Material Weakness 2022

Government of the District of Columbia

DC

Eligibility Special Tests & Provisions Student Financial Aid § 200.303

The Department of Human Services (DHS) agrees with the finding in this report. The DCAS System is currently configured to receive the Title II benefit information via the SSA BENDEX periodic data match process. However, the Title II benefit information is shared with DCAS only when the benefit info...

The Department of Human Services (DHS) agrees with the finding in this report. The DCAS System is currently configured to receive the Title II benefit information via the SSA BENDEX periodic data match process. However, the Title II benefit information is shared with DCAS only when the benefit information with the SSA changes. In the scenario where a TANF benefit is certified on a new application, the BENDEX PDM process will not provide the Title II benefit information to DCAS. Hence, we have seen evidence of the data matches not happening up until the point when the benefit information recorded with SSA has changed. The SSA SolQi interface does provide a customer?s Title II and Title XVI benefit information at the time of the initial application, however, this interface in DCAS is configured as a verification interface. In other words, if the customer has reported income from the Social Security Administration, then the DCAS System uses the data match with the SolQi interface to verify the information reported. If a verification is outstanding on the reported benefit from the SSA, and the information received from SolQi matches, then DCAS system is configured to systematically resolve the verification. Hence, there has been evidence of the record received via SolQi, however, the record was not used to update the internal evidence which is used by the eligibility rules. DHCF DCAS teams are tracking system enhancements, logged in internal JIRA tickets ? DSM-3185 and DSM-3186 to enhance DCAS? interface with SolQi to leverage the interface at initial application and during the recertification process to ensure that the DCAS System has the most up to date income information from SSA to determine eligibility. These tickets are currently scoped for the FNS-AWL-CAP-5 releases planned for fiscal year 2024. See Corrective Action Plan for chart/table

View Audit 31369

Finding 36683 (2022-001)

Significant Deficiency 2022

Webster University

MO

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

The Financial Aid Office and the Registrar's Office will work closely together to resolve the NSLDS reporting discrepancies. We are currently in the process of hiring a Compliance Coordinator that will serve as a bridge between the Financial Aid Office and the Registrar's office that will monitor a...

The Financial Aid Office and the Registrar's Office will work closely together to resolve the NSLDS reporting discrepancies. We are currently in the process of hiring a Compliance Coordinator that will serve as a bridge between the Financial Aid Office and the Registrar's office that will monitor and audit the reporting process for errors and discrepancies monthly. From here, if there are any discrepancies or inconsistencies, the Financial Aid Office and the Registrar's Office will work together to understand any patterns that exist so that our processes can be reevaluated and tightened to ensure ongoing compliance. Based on the review of information from last year's similar finding (2021), it was determined after the fact that Webster University had both reported the enrollment information correctly and in a timely manner to the Clearinghouse, however, the Clearinghouse frequently reported glitches and outages that prevented reporting to NSLDS in a timely manner. Going forward the Compliance Coordinator will monitor enrollment reporting, as well as the timing of the Clearinghouse's enrollment reporting to NSLDS. If it is determined that enrollment reporting via the Clearinghouse continues to be discrepant, Webster University will explore other methods of reporting that are more conducive to timely and accurate enrolment reporting to NSLDS.

View Audit 35724

Finding 36283 (2022-024)

None 2022

Government of the District of Columbia

DC

Student Financial Aid Reporting School Nutrition Programs § 200.512

The District concurs with the auditor?s finding. The delay in the report submission is due to unusual circumstances and events during the fiscal year. We will communicate to the appropriate personnel the importance of providing requested documents and responding to auditor inquiries in a timely man...

The District concurs with the auditor?s finding. The delay in the report submission is due to unusual circumstances and events during the fiscal year. We will communicate to the appropriate personnel the importance of providing requested documents and responding to auditor inquiries in a timely manner. See Corrective Action Plan for chart/table

View Audit 31369

Finding 36151 (2022-002)

Significant Deficiency 2022

Wesley Theological Seminary of the United Methodist Church

DC

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking

2022-002 Eligibility ? Maintain good standing or satisfactory academic progress Contact: Jeffrey C. Straits Title: Chief Financial Officer Phone Number: (202)885-8684 Anticipated Completion Date- Done Corrective Action Wesley Theological Seminary will ensure that students maintain a good sta...

2022-002 Eligibility ? Maintain good standing or satisfactory academic progress Contact: Jeffrey C. Straits Title: Chief Financial Officer Phone Number: (202)885-8684 Anticipated Completion Date- Done Corrective Action Wesley Theological Seminary will ensure that students maintain a good standing or satisfactory academic progress in order to be eligible for Federal direct student loans per the OMB Compliance Supplement. Wesley acknowledges that before the outsourcing of our financial aid processing, there was a breakdown in the seminary following policies, procedures, and controls, which allowed this error. The Seminary will review all policies and procedures related to this control and develop ways to strengthen these controls. Wesley will also complete a review of all active federal loans for the fiscal year 2022 to identify if there are further processing errors allowing loans to students without maintaining good standing or satisfactory academic progress to be eligible for Federal direct student loans. Wesley management will also implement quarterly testing of randomly selected student loan transactions. The testing will include the verification of eligibility for aggregate loan totals, good standing, and satisfactory academic progress. The results of this testing will be reviewed by the CFO and maintained by Wesley?s management. Status as of November 2022 Wesley Theological Seminary outsourced our financial aid processing in January 2022. The error found was processed by our internal Financial Aid Director before the outsourcing of financial aid. Wesley has reviewed our policies and procedures related to this issue. We will add to the policies and procedures that the CFO will also approve all appeals approved by the Financial Aid Committee for lack of a student?s adequate satisfactory academic progress. The CFO?s approval will also be maintained with the appeal records of the Financial Aid Committee. We completed the review of all students who received Federal financial aid in the fiscal year 2022. There were no other students with inadequate satisfactory academic progress other than the one previously identified by BDO. Our outsourced financial aid processor will ensure the review of satisfactory academic progress prior to processing a loan, as required in our policies and procedures. To verify ongoing compliance of our outsourced financial aid processor with our financial aid policies, procedures, and controls, we are adding a requirement of quarterly random testing of students? records for the verification of eligibility for aggregate loan totals, good standing, and satisfactory academic progress. Wesley management has completed the fiscal year 2023 first quarter review of random students? transactions, and we did not find any errors. The testing results were reviewed by the CFO and maintained by Wesley?s management.

View Audit 25603

Finding 36150 (2022-001)

Material Weakness 2022

Wesley Theological Seminary of the United Methodist Church

DC

Questioned Costs Student Financial Aid Eligibility § 200.91

2022-001 Eligibility ? Aggregate Loan Limits for Subsidized and Unsubsidized Loans Contact: Jeffrey C. Straits Title: Chief Financial Officer Phone Number: (202)885-8684 Anticipated Completion Date- Done Corrective Action Wesley Theological Seminary will ensure that the loans disbursed by th...

2022-001 Eligibility ? Aggregate Loan Limits for Subsidized and Unsubsidized Loans Contact: Jeffrey C. Straits Title: Chief Financial Officer Phone Number: (202)885-8684 Anticipated Completion Date- Done Corrective Action Wesley Theological Seminary will ensure that the loans disbursed by the Institution are within the loan limits prescribed in the OMB Compliance Supplement. Wesley acknowledges that before outsourcing our financial aid processing, there was a breakdown in the Seminary following policies, procedures, and controls within financial aid, which allowed these errors. The Seminary will review all policies and procedures related to this control. We will also complete a review of all active federal loans for the fiscal year 2022 to identify if there are further processing errors allowing loans above the aggregate loan limits. Wesley management will also implement quarterly testing of randomly selected student loan transactions. The testing will include the verification of eligibility for aggregate loan totals, good standing, and satisfactory academic progress. The results of this testing will be reviewed by the CFO and maintained by Wesley?s management. Status as of November 2022 Wesley Theological Seminary outsourced our financial aid processing in January 2022. Wesley will ensure the work prepared by outsourced personnel is reviewed properly and such review is documented properly. All of the errors found were processed by our internal Financial Aid Director before the outsourcing of financial aid processing. We completed the review of all students who received Federal financial aid in the fiscal year 2022. There were seven students with awards over the aggregate maximum (including those previously identified by BDO). The total amount awarded over the per-person aggregate limit was $79,159. Our outsourced financial aid processor will ensure the review of total student debt prior to processing a loan, as required in our policies and procedures. Wesley management has reviewed our policies and procedures related to this issue. To verify ongoing compliance of our outsourced financial aid processor with our financial aid policies, procedures, and controls, we are adding a requirement of quarterly random testing of students? records for the verification of eligibility for aggregate loan totals, good standing, and satisfactory academic progress. Wesley management has completed the fiscal year 2023 first quarter review of random students? transactions, and we did not find any errors. The testing results were reviewed by the CFO and maintained by Wesley?s management.

View Audit 25603 Questioned Costs: $1

Finding 36144 (2022-004)

Significant Deficiency 2022

William Jewell College

MO

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

Personnel Responsible for Corrective Action: Daniel Holt, Chief Financial Officer Anticipated Completion Date: June 30, 2023 Corrective Action Plan: The College will properly impleme...

Personnel Responsible for Corrective Action: Daniel Holt, Chief Financial Officer Anticipated Completion Date: June 30, 2023 Corrective Action Plan: The College will properly implement the February 2022 Information Security Plan and maintain effective internal controls, perform risk assessments, establish safeguards and document identified risks. The information technology office and security committee will ensure all activities are performed per institutional policy and generate reports for the institutional compliance committee and CFO for presentation to management.

View Audit 25565

Finding 36115 (2022-002)

None 2022

Mount Mercy University

IA

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

Identifying Number: 2022-002 Finding: Students were never awarded and disbursed FDL funds and under awarded an disbursed FSEOG funds. Corrective Actions Taken or Planned: Students identified were awarded aid to cover the error on 6/30/22. All student enrollment is checked at the start of the t...

Identifying Number: 2022-002 Finding: Students were never awarded and disbursed FDL funds and under awarded an disbursed FSEOG funds. Corrective Actions Taken or Planned: Students identified were awarded aid to cover the error on 6/30/22. All student enrollment is checked at the start of the term; however, our modular students are allowed to make schedule changes throughout the semester. A report has been generated to review enrollment changes weekly to properly update any necessary aid changes. Persons Responsible and Completion Date: Mark Freed, Director of Financial Aid, June 30, 2022

View Audit 31077 Questioned Costs: $1

Finding 36113 (2022-001)

None 2022

Waubonsee Community College District 516

IL

Questioned Costs Student Financial Aid Internal Control / Segregation of Duties

2022-001 Federal Work Study - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2022 Condition Found During...

2022-001 Federal Work Study - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2022 Condition Found During our Federal Work Study testing, we selected eleven students and noted that one student was paid for hours they did not work. The College did not review federal work-study hours worked against class hours scheduled and timesheets to ensure the student was not working during a scheduled class and that they were paid for the correct number of hours. We consider this condition to be an instance of non-compliance to the Activities Allowed or Unallowed compliance requirement. Corrective Action Plan In addition to direct counseling with the supervisor and student workers partied to this practice, the Financial Aid and Human Resources offices implemented several steps to stress the supervisor?s responsibility for timesheet validation. The changes went into effect on August 5, 2022. The steps included: 1. Reviewed the Student Worker Employee Handbook and Student Worker Supervisor Handbooks to confirm that language exists addressing that students should not work during scheduled class time, and supervisors are responsible for reviewing timesheets before approval submission. 2. All Supervisors are now required to review and sign off on the Supervisor Student Worker Handbook annually. Human Resources will audit for compliance quarterly. 3. At the start of each new academic year, Financial Aid and Human Resources will host a ?Hiring a Student Worker Information? session for all supervisors. This year the session took place on September 1, 2022. This session stress timesheet reviews, among many other responsibilities. Responsible Person for Corrective Action Plan Mary Greenwood, Director of Student Financial Aid Services, will be the person responsible for this Corrective Action Plan. Implementation Date of Corrective Action Plan As of August 5, 2022, all phases of the Corrective Action Plan were implemented.

View Audit 31075 Questioned Costs: $1

Finding 36064 (2022-002)

Material Weakness 2022

Hawaii Pacific University

HI

Student Financial Aid Reporting Internal Control / Segregation of Duties § 200.328 § 200.329

Views of Responsible Officials and Planned Corrective Action The HPU Office of Sponsored Projects (OSP) and Office of Financial Aid work to follow all federal reporting regulations and guidance mandated for the Federal grant & contract programs. For future programs, the Institutional Research, th...

Views of Responsible Officials and Planned Corrective Action The HPU Office of Sponsored Projects (OSP) and Office of Financial Aid work to follow all federal reporting regulations and guidance mandated for the Federal grant & contract programs. For future programs, the Institutional Research, the Office of Sponsored Projects and the Financial Aid Office will generate the reports and will implement layers of review procedure to ensure that the reports are accurate, complete, submitted timely, and if needed, posted in HPU website. For the Institution portion, the Manager for Grants and Contracts will prepare the grant report and this report will be reviewed by the Assistant VP for OSP. For the student portion the periodic reports will be prepared by the staff of the Office of Financial Aid and will be reviewed by the Director of the Financial Aid office. The Business Office will perform a high-level independent review for completeness and accuracy. Finally, moving forward, all the files and documents that support the grant report will be retained. Person Responsible: Manager, for Office of Sponsored Projects & Assistant VP for Office of Sponsored Projects, Director of Financial Aid Targeted Correction Date: June 30, 2023.

View Audit 34010

Finding 36063 (2022-001)

Material Weakness 2022

Hawaii Pacific University

HI

Allowable Costs / Cost Principles Student Financial Aid § 200.303

Views of Responsible Officials and Planned Corrective Action The HPU Financial Aid Office works hard to follow all federal regulations and guidance mandated for the Title IV Federal Student Aid programs. In regards to the distribution of the Federal HEERF fund to HPU students, the HPU Financial Aid...

Views of Responsible Officials and Planned Corrective Action The HPU Financial Aid Office works hard to follow all federal regulations and guidance mandated for the Title IV Federal Student Aid programs. In regards to the distribution of the Federal HEERF fund to HPU students, the HPU Financial Aid Director relied on reports from the SIS (Banner system), Institutional Research, and Accounts Receivable to determine students eligible for HEERF funds. The HPU Financial Aid Office and Office of Sponsored Projects worked hard, and diligently, to award funds to students and expend Institution portion based on the regulations that were provided at the time and not violating the intent of the program, as evidenced by there not being any non-compliance over allowability of costs charged to Federal HEERF fund. For future awards, the Principal Investigator with the assistance of the Office of Sponsored Projects will review diligently the expenditure to be sure the expenditures are within the allowability and terms and conditions of the federal awards. Both offices will work collaboratively so that the internal controls over allowability are strengthened and that the documentation will be strongly implemented and retained. For future programs, the HPU Financial Aid will work to strategically plan, organize, and disburse funds to students and expend Institution funds within the requirements mandated by the United States Department of Education, including strengthening our internal controls over compliance, and increasing the documentation and maintenance of documentation over our existing internal controls for compliance. Person Responsible: Manager, for Office of Sponsored Projects & Assistant VP for Office of Sponsored Projects, Director of Financial Aid Targeted Correction Date: June 30, 2023.

View Audit 34010

Finding 35997 (2022-002)

Significant Deficiency 2022

Cambridge College

MA

Student Financial Aid Special Tests & Provisions Reporting

Contact person(s) responsible for corrective action - Amy Cavelier and Robert Wagstaff, Registrar?s Office Anticipated completion date ? August 31, 2023 Corrective Action The Registrar?s office will ensure proper controls and processes are in place to ensure program-level effective date information...

Contact person(s) responsible for corrective action - Amy Cavelier and Robert Wagstaff, Registrar?s Office Anticipated completion date ? August 31, 2023 Corrective Action The Registrar?s office will ensure proper controls and processes are in place to ensure program-level effective date information is properly and timely submitted to the NSLDS. Timeframe: June through August 2023 Responsible Parties: Amy Cavelier and Robert Wagstaff Goal: Registrar management and staff are working with the College?s Student Information Systems and IT departments to verify when and how the conflicting program-level effective dates were entered. At this point, we believe that the data originating from Jenzabar is correct. Discrepancies were created during the NSC error cleaning process, and data including those discrepancies were reported to the NSC and subsequently the NSLDS. Registrar?s Office management and staff are working with the NSLDS to obtain final student data reports which will be compared to the monthly student data files originally submitted to the NSC, prior to error correction, to identify the discrepancies and the cause of the data errors. The College is transitioning the enrollment reporting responsibility to another member of the Registrar?s Office. This transition will include formal training on the Jenzabar student information system, with a particular focus on NSLDS data reporting, as well as the NSC and NSLDS data submission processes. Our first Jenzabar training sessions have been scheduled for June 30 and July 7, 2023.

View Audit 33821

Corrective Action Plans

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