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Corrective Action Plans

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Finding 34447 (2022-003)
Significant Deficiency 2022
American Academy McAllister Institute of Funeral Service, Inc.
NY
Student Financial Aid Questioned Costs Special Tests & Provisions
Recommendation: The auditors recommended that the Institute continue its efforts to ensure all required exit counseling procedures are conducted and documented in compliance with U.S. Department of Education regulations. Action Taken: We agree with both the finding and the recommendation. The inst...
Recommendation: The auditors recommended that the Institute continue its efforts to ensure all required exit counseling procedures are conducted and documented in compliance with U.S. Department of Education regulations. Action Taken: We agree with both the finding and the recommendation. The instances of missed exit conferences with borrowers under the Federal Direct Loan Program were primarily related to students who had been dropped due to non-payment of tuition and who did not respond to our attempts to contact them for an exit conference. We understand that we failed to properly document our efforts to contact these students to schedule and perform an exit conference. We have amended our procedures to document our efforts to contact any students for which an exit conference is required and we have not been able to schedule one.
View Audit 30410
Finding 34387 (2022-001)
Material Weakness 2022
Columbia International University and Subsidiaries
SC
Student Financial Aid Questioned Costs Material Weakness
Finding Number: 2022-001 Untimely Returns of Title IV Funds and Inaccurate Returns of Title IV Funds (R2T4) Planned Corrective Action: Three of the four students with inaccurate return of Title IV fund calculations were corrected during the audit. FA Office is in the process of reaching out to the...
Finding Number: 2022-001 Untimely Returns of Title IV Funds and Inaccurate Returns of Title IV Funds (R2T4) Planned Corrective Action: Three of the four students with inaccurate return of Title IV fund calculations were corrected during the audit. FA Office is in the process of reaching out to the student with an over-return of $418 in FDL for authorization to disburse this amount. FA Office has met with Assistant Registrar for Online Studies and Academic Advising to review the federal regulations for R2T4 in modular programs. The Online Advising and Registrar team were provided with a list of module withdrawal questions that should help to determine if a student is a withdrawal. A copy of questions that were provided to those teams is attached. The following procedures were established between both offices to eliminate untimely and inaccurate return of Title IV funds going forward: If a student is dropped for inactivity/nonparticipation, the remainder of their courses for that payment period are dropped as well. This allows the return of unearned Title IV funds to be completed no later than 45 days after the school determines the LDA. If a student would like to take a break and return to a module that begins later in the payment period, they must provide a statement of intent to return (written confirmation) and the module must begin no later than 45 calendar days after the end of the module the student ceased attending. Financial Aid also met with Associate Registrar and CIU Database Developer to create a report that better captures students who are determined as withdrawals in modular programs. This will assist in monitoring the online student population and achieve more accuracy in reporting. Online Financial Aid team has redistributed workload so that the Associate Director has more time designated to monitor and oversee the R2T4 process. Person Responsible for Corrective Action Plan: Patty Hix, Director of Financial Aid and Lynsay Shumpert, Associate Director for Online Studies Anticipated Date of Completion: Report has been created and we are in the testing phase.
View Audit 30211
Finding 34377 (2022-001)
Material Weakness 2022
Michigan Barber School
MI
Student Financial Aid Reporting Matching / Level of Effort / Earmarking
FINDING 2022-001-Late Notification to NSLDS
FINDING 2022-001-Late Notification to NSLDS
View Audit 35710
Saint Elizabeth University
NJ
Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking
Federal Direct Loans Reconciliations Planned Corrective Action: The University will ensure that incomplete reconciliation is completed for 2021-2022. We will ensure that monthly reconciliation is completed as required as follows: 1. Monthly reconciliations will be signed by the Director of Financ...
Federal Direct Loans Reconciliations Planned Corrective Action: The University will ensure that incomplete reconciliation is completed for 2021-2022. We will ensure that monthly reconciliation is completed as required as follows: 1. Monthly reconciliations will be signed by the Director of Financial Aid and Vice President for Enrollment Management Person Responsible for Corrective Action Plan: Sheri Jefferson, Interim Director of Financial Aid Anticipated Date of Completion: June 30, 2023
View Audit 28719
Presbyterian College
SC
Special Tests & Provisions Questioned Costs Student Financial Aid
Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) For 1 of 25 students tested, the College was unable to locate Perkins promissory note related to this st...
Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) For 1 of 25 students tested, the College was unable to locate Perkins promissory note related to this student. Corrective Action Plan: The College maintains all Perkins promissory notes in alphabetical order, in a dedicated filing cabinet, in a fireproof vault. This finding relates to a promissory note that was signed in 1987 and the College is not aware of what may have caused this Promissory note to be misplaced. No further action is planned by Management as the Perkins Loan Program expired on September 30, 2017 and no additional Perkins Loan disbursements were made by the College since the Program?s expiration. Anticipated Completion Date: March 1, 2023
View Audit 29056
Presbyterian College
SC
Questioned Costs Special Tests & Provisions Student Financial Aid
Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) For 1 of 2 students selected for testing, the College did not return the correct amount to COD. Correct...
Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) For 1 of 2 students selected for testing, the College did not return the correct amount to COD. Corrective Action Plan: As of September 2022, the Office of Financial Aid began utilizing the R2T4 Worksheet found on COD. This more clearly and specifically states the net total that should be returned. Anticipated Completion Date: September 1, 2022
View Audit 29056 Questioned Costs: $1
Presbyterian College
SC
Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking
Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) For 1 of 40 students tested, the College was unable to provide a copy of the award disbursement notifica...
Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) For 1 of 40 students tested, the College was unable to provide a copy of the award disbursement notification letter sent to student and or parent for parent plus borrowers, which includes the amount of funds the student and his or her parent can expect to receive from each FSA program and how and when those funds will be disbursed. Corrective Action Plan: The College recognizes that when Direct Loan funds are being credited to a student?s ledger account (except in the case of loan funds made as part of a post-withdrawal disbursement), the school must notify the borrower in writing (paper or electronically) of the: ? anticipated date and amount of the disbursement; ? student?s or parent?s right to cancel all or a portion of a loan or loan disbursement and have the loan proceeds returned to the Department; and ? procedures and deadlines by which the student or parent must notify the school that he or she wishes to cancel the loan or loan disbursement. The timing of a loan notification varies depending on whether a school obtains affirmative confirmation from a student that he or she wants a loan. Affirmative confirmation is a process under which a school obtains written confirmation of the types and amounts of Title IV loans a student wants for the period of enrollment before the institution credits the student?s account with those loan funds (34 CFR 668.165(a)(6)). Presbyterian College requires students to accept Direct Loan awards in BannerWeb so notifications are sent according to requirements when a student actively confirms the loan. Disbursement notifications were sent to students after each disbursement during the 2021-2022 academic year; however, the parent was not directly notified of a PLUS loan disbursement. For the 2023-2024 academic year, a PLUS Loan Form has been created and will be sent to the parent borrower to confirm the amount requesting. As of March 6, 2023, notifications are being created to notify parents with PLUS loans of disbursement and their rights. Anticipated Completion Date: March 6, 2023
View Audit 29056
Finding 34266 (2022-004)
Significant Deficiency 2022
Presbyterian College
SC
Student Financial Aid Subrecipient Monitoring Eligibility
Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) For 2 of 2 mid-year transfer students tested, the school did not actively add these students to the NSLD...
Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) For 2 of 2 mid-year transfer students tested, the school did not actively add these students to the NSLDS transfer monitoring list. Corrective Action Plan: The College acknowledges the requirement that schools obtain financial aid history information for their transfer students. Due to the small number of transfer students accepted by the College, it is the College?s belief that it followed US Department of Education guidance allowing a school to use NSLDS information for a mid-year transfer student if it obtained that information no earlier than 30 days prior to the first day of the student?s payment period (Dear Partner Letter GEN 00-12). The new Director of Financial Aid works closely with the Office of Admission and will update NSLDS manually to ?inform? it of the transfer students applying to PC mid-year. This is a relatively small group of students. For those students included on a school?s ?Inform? list, NSLDS ?Monitors? changes to the student?s financial aid history that have occurred since the latest ISIR for the student was generated and sent to the school. NSLDS will continue to monitor changes to the student?s financial aid history, and alert the school of any subsequent relevant changes. A staff member in the Office of Financial Aid will be assigned to review the Transfer Monitoring files. Anticipated Completion Date: March 1, 2023
View Audit 29056
Finding 34213 (2022-001)
Significant Deficiency 2022
Dysart Unified School District No. 89
AZ
School Nutrition Programs Student Financial Aid Allowable Costs / Cost Principles
Findings and Questioned Costs Related to Federal Awards Finding Number: 2022-001 Contact Person: Dr. Shelley Isai, Assistant Superintendent for Education Services Anticipated Completion Date: November 21, 2022 Planned Corrective Action: The District reviewed the procedures used to determine Tit...
Findings and Questioned Costs Related to Federal Awards Finding Number: 2022-001 Contact Person: Dr. Shelley Isai, Assistant Superintendent for Education Services Anticipated Completion Date: November 21, 2022 Planned Corrective Action: The District reviewed the procedures used to determine Title I, Part A eligibility in the Grants Management System as well as a process that includes maintaining records. The process was redefined for the fiscal year 2023 grant application but will change slightly in future years due to a change in the options in criteria available used to determine eligibility for fiscal year 2023 grant applications. To complete this process with accuracy, the Director of Federal Projects will communicate the required eligibility criteria to the Director of Nutrition Services. The Nutrition Services department will provide Federal Projects with the necessary information to complete the process. Supporting documentation for the basis of fiscal year 2023 and the future years will be stored in a shared file and readily accessible for reference or audits. This process has been documented to ensure consistency through any department transitions.
View Audit 36747
Finding 34122 (2022-001)
Significant Deficiency 2022
Texas Wesleyan University
TX
Questioned Costs Special Tests & Provisions Student Financial Aid
Texas Wesleyan University Corrective Action Plan 2021 Academic Year (Summer 21, Fall 21, Spring 22) Fiscal Year Ending May 31, 2022 Reference Number: 2022-001 Recommendation: The University should update its controls to ensure that the days attended for students who withdraw from a program offered i...
Texas Wesleyan University Corrective Action Plan 2021 Academic Year (Summer 21, Fall 21, Spring 22) Fiscal Year Ending May 31, 2022 Reference Number: 2022-001 Recommendation: The University should update its controls to ensure that the days attended for students who withdraw from a program offered in modules is correct. Corrective Action Plan: The Financial Aid Administrator acknowledges the error with the Title IV Calculation for the student who was enrolled in two modules in one semester. Initially, the calculation was based on the student being enrolled in one module. When the file was chosen for the 2021-2022 audit, the error was caught that the student was enrolled in module two, as well. The Director of Financial Aid has reached out to ?Ask a Fed? for guidance on the calculation of the numerator in a Title IV calculation about modules. The guidance was received on September 1, 2022, and confirmed that the numerator should only include the actual days the student attended. This guidance has been implemented. The 2021-2022 return of funds for students enrolled in the modules will be recalculated by October 31, 2022.
View Audit 33599
Finding 34115 (2022-001)
Significant Deficiency 2022
Central Wyoming College
WY
Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring
Student Financial Aid Cluster Status Change Not Reported Enrollment Reporting The Student Financial Aid Office and the Office of Student Records will work closely to ensure students? date of withdrawal from all courses are entered into Colleague correctly and that both offices? dates match. The ...
Student Financial Aid Cluster Status Change Not Reported Enrollment Reporting The Student Financial Aid Office and the Office of Student Records will work closely to ensure students? date of withdrawal from all courses are entered into Colleague correctly and that both offices? dates match. The Office of Student Records will provide the National Clearinghouse enrollment reporting dates for Central Wyoming College to the Financial Aid Office. This will ensure the Financial Aid Office provides the Office of Student Records with the Return to Title IV student report in a timely manner for reporting to the National Clearinghouse. The Registrar will make sure any student on the Return to Title IV list has a record on the National Clearinghouse for program-level and campus-level reporting. The Registrar will verify all students on the Return to Title IV list are showing correctly on the National Clearinghouse upon submittal. The Director of Financial Aid will review NSLDS monthly to ensure status dates for all Return to Title IV students are accurately reflected. The Director of Financial Aid will also communicate any issues found with any student?s status on the NSLDS site to the Registrar. The Director of Financial Aid, in collaboration with the Office of Student Records, will work to obtain and review the SOC 1 report from the third-party servicer (National Clearinghouse) to ensure proper controls are implemented. Anticipated Completion Date: December 1, 2022 Contact Person(s): DeeAnna Archuleta, SFA Director Connie Nyberg, Registrar
View Audit 24446
Lewis & Clark College
OR
Student Financial Aid Reporting Matching / Level of Effort / Earmarking
October 14, 2022 U.S. Department of Education 400 Maryland Avenue, SW Washington, D.C. 20202 Re: Corrective Action Plan Finding 2022-001 Program: Federal Direct Loan Programs CFDA Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K22059 Federal Awar...
October 14, 2022 U.S. Department of Education 400 Maryland Avenue, SW Washington, D.C. 20202 Re: Corrective Action Plan Finding 2022-001 Program: Federal Direct Loan Programs CFDA Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K22059 Federal Award Year: June 30, 2022 Condition For 3 of 25 students included in our sample, the enrollment status was reported incorrectly. Two students were enrolled in Law Masters degree programs and were reported as less than full-time although should have been full time. Additionally, one GSEC Masters student was reported correctly on the program level enrollment reporting as withdrawn on March 15, 2022, however, the campus level reporting included an incorrect status of less than half time and status date of March 16, 2022 before later being corrected to withdrawn status date of March 15, 2022. The sample was not a statistically valid sample. Corrective Action Plan Management agrees with the finding, and is committed to strengthening its procedures to avoid similar issues in the future. The College has reconfirmed the full and part time definitions for Law Masters students, and corrected the underlying technical issue that had interfered with the reporting of correct enrollment statuses for Law Master's students. The correction of the enrollment status for the two Law Masters students in NSLDS is in process. The College has also updated the procedures and documentation for enrollment reporting of GSEC Masters students to ensure the scenario identified is handled correctly and consistently in the future. The College has corrected this student's program level withdrawal date in NSLDS. Lewis & Clark College Andrea Dooley Chief Financial Officer and Vice President of Operations
View Audit 29630
Finding 34006 (2022-001)
Material Weakness 2022
Alexander County
NC
Questioned Costs Student Financial Aid Eligibility
CORRECTIVE ACTION PLAN Program Name: Foster Care Title IVE Finding: 2022-001 Name of Contact: Keri Jerrell, Child Welfare Program Manager Corrective Action Plan: As children enter foster care, a DSS-5120 is required to be completed in order to determine foster care funding eligibility. Once determin...
CORRECTIVE ACTION PLAN Program Name: Foster Care Title IVE Finding: 2022-001 Name of Contact: Keri Jerrell, Child Welfare Program Manager Corrective Action Plan: As children enter foster care, a DSS-5120 is required to be completed in order to determine foster care funding eligibility. Once determined, the eligibility is used in a variety of ways, including, administrative coding and payment for room and board services. As both of these areas involve fiscal operations and county, state, and federal funds, proper determination is imperative. Once satisfied that the proper determination has been made, proper communication and transfer of that determination is of equal importance. In order to assure that a prompt and efficient foster care funding determination is made for each child entering custody of the Alexander County Department of Social Services, the Department is adopting the following plan: 1. Internal guidance for completing the initial DSS-5120 and all subsequent DSS-5120 reviews will be developed and implemented. Guidance will include specialized training for identified staff and a multi-party review process. Projected completion date: 12-31-22 2. 100% of Alexander County DSS cases will be reviewed to ensure that the original funding determination cited on the DSS-5120 is reflected on the respective DSS-5094. Projected completion date: 11-30-22 3. Existing internal guidance document involving the use of the PQA-020 report will be reviewed with involved staff, stressing the importance of consistent documentation of funding source. Projected completion date: 11-30-22
View Audit 35515 Questioned Costs: $1
Finding 33996 (2022-001)
Material Weakness 2022
University of the Southwest
NM
Student Financial Aid Questioned Costs Matching / Level of Effort / Earmarking
Incorrect and Untimely Return of Title IV (R2T4) Funds Planned Corrective Action: The Financial Aid Office reviewed the new modular regulations and guidance again as it was identified that exemption(s) were missed in the initial review. The team updated the 2021 NASFAA R2T4 decision tree with notes...
Incorrect and Untimely Return of Title IV (R2T4) Funds Planned Corrective Action: The Financial Aid Office reviewed the new modular regulations and guidance again as it was identified that exemption(s) were missed in the initial review. The team updated the 2021 NASFAA R2T4 decision tree with notes breaking down the complexity of the new modular regulations and how they apply to our modules/programs. The unofficial withdrawal list for the academic year was re-requested from the registrar?s office and reviewed. Students that met exemption were awarded funds back, recalculated if needed, and processed. Although the Financial Aid Office did implement changes on identifying unofficial withdraws (students were identified) from the prior year finding, the complexity of the modular regulations impacted the finding for 2022. A review of each student?s module will be performed (Executive Director of Financial Aid / Lead Director) and then reviewed and processed by staff member (Financial Aid Director). The final determination list will be compared to the R2T4?s processed. Person Responsible for Corrective Action Plan: Sandy Wilkinson, Executive Director of Financial Aid Anticipated Date of Completion: Implemented
View Audit 34177 Questioned Costs: $1
Finding 33990 (2022-004)
Significant Deficiency 2022
The Thomas More College of Liberal Arts, Inc.
NH
Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking
Finding 2022-004: Information on the Federal Program Federal Agency: United States Department of Education (ED) Program Name: Student Financial Assistance Cluster AL: 84.268 - Federal Direct Student Loans Federal Award Identification Number: N/A Federal Award Year: Year Ended May 31 , 2022 The Colle...
Finding 2022-004: Information on the Federal Program Federal Agency: United States Department of Education (ED) Program Name: Student Financial Assistance Cluster AL: 84.268 - Federal Direct Student Loans Federal Award Identification Number: N/A Federal Award Year: Year Ended May 31 , 2022 The College will implement a control procedure to ensure disbursement notification letters are sent to every student who received direct loan disbursement, within 7 days, to be in compliance with the requirement described above. The College supplies to the student a notification of each disbursement via a Statement of Account. The College has added a clause in the Terms and Conditions which addresses the cancelation of loans. Estimated Completion Date: December 31 , 2022 Contact Person: Pamela A. Bernstein Director of Business and Registrar Affairs thomasmorecollege@hotmail.com 603-324-1420
View Audit 31753
Worknet Pinellas, Inc.
FL
Eligibility Questioned Costs Student Financial Aid
WorkNet Pinellas, Inc. management and MIS Team reviewed the monitoring issue with the WIOA team and provided training on the subject. WorkNet Pinellas, Inc. has improved the enrollment process, hired an eligibility specialist and implemented Quality Control (QC) processes to include a review by the...
WorkNet Pinellas, Inc. management and MIS Team reviewed the monitoring issue with the WIOA team and provided training on the subject. WorkNet Pinellas, Inc. has improved the enrollment process, hired an eligibility specialist and implemented Quality Control (QC) processes to include a review by the eligibility specialist, Career Counselor, and WIOA Lead or MIS QC prior to enrollment to ensure eligibility and accuracy and to ensure "training services be limited to individuals who are unable to obtain other grant assistance for such services including Federal Pell Grants."
View Audit 29741
The King's College and Subsidiaries
NY
Student Financial Aid Matching / Level of Effort / Earmarking
Federal Direct Loans and Pell Grants Reconciliations Planned Corrective Action: Implement a procedure where Pell Grants and Direct Loans are reconciled by student using reports from CAMS as well as COD. Person Responsible for Corrective Action Plan: Anna Peters Anticipated Date of Completion: May 31...
Federal Direct Loans and Pell Grants Reconciliations Planned Corrective Action: Implement a procedure where Pell Grants and Direct Loans are reconciled by student using reports from CAMS as well as COD. Person Responsible for Corrective Action Plan: Anna Peters Anticipated Date of Completion: May 31, 2023
View Audit 29133
Finding 33903 (2022-001)
Significant Deficiency 2022
The King's College and Subsidiaries
NY
Questioned Costs Student Financial Aid Significant Deficiency
Inaccurate Return of IV (R2T4) Funds Planned Corrective Action: A review of all R2T4s performed for students in our on-line program will be completed. The review will include recalculating Pell Grants for students that did not begin attendance in courses. It will also include adding the break betwee...
Inaccurate Return of IV (R2T4) Funds Planned Corrective Action: A review of all R2T4s performed for students in our on-line program will be completed. The review will include recalculating Pell Grants for students that did not begin attendance in courses. It will also include adding the break between modules into the dates on the R2T4. Person Responsible for Corrective Action Plan: Anna Peters Anticipated Date of Completion: May 31, 2023
View Audit 29133
Finding 33832 (2022-001)
Material Weakness 2022
Clarke University of Dubuque, Iowa
IA
Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties
Finding 2022-001 Student Financial Assistance Program Cluster -Department of Education Federal Financial Assistance Listing/CFDA #84.038 Federal Perkins Loan Program Reporting Material Weakness in Internal Control over Compliance Finding Summary: The information reported on the FISAP was incorrect...
Finding 2022-001 Student Financial Assistance Program Cluster -Department of Education Federal Financial Assistance Listing/CFDA #84.038 Federal Perkins Loan Program Reporting Material Weakness in Internal Control over Compliance Finding Summary: The information reported on the FISAP was incorrect. Responsible Individuals: Robert Hoover, Director of Financial Aid and Deb Theill, Student Accounts Loan Coordinator Corrective Action Plan: The figures reported were corrected with no negative impact to the report or institution. Responsible parties will incorporate a second round of review to analyze data entry and eliminate errors moving forward. Anticipated Completion Date: Updates Completed 9/1/2022
View Audit 31739
Finding 33828 (2022-004)
Significant Deficiency 2022
Clarke University of Dubuque, Iowa
IA
Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking
Finding 2022-004 Student Financial Assistance Program Cluster - Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2021/2022 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell .Grant Program - 2021/2022 P063P201430 Specia...
Finding 2022-004 Student Financial Assistance Program Cluster - Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2021/2022 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell .Grant Program - 2021/2022 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control Finding Summary: Two instances were noted where enrollment effective date reported to the National Student Clearing House as first effective was not the same as the student's last date of attendance. Responsible Individuals: Kristi Bagstad, Registrar Registrar's Office Corrective Action Plan: The financial aid office will establish a review process to spot-check and confirm that the Enrollment Effective date will coincide with the Last Day of Attendance reported for student records. Anticipated Completion Date: Ongoing
View Audit 31739
Finding 33827 (2022-003)
Material Weakness 2022
Clarke University of Dubuque, Iowa
IA
Student Financial Aid Material Weakness Reporting
Finding 2022-003 Student Financial Assistance Program Cluster - Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2020/2021 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2020/2021 P063P201430 Reporti...
Finding 2022-003 Student Financial Assistance Program Cluster - Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2020/2021 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2020/2021 P063P201430 Reporting- Common Origination and Disbursement System Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary: Three instances were noted where Title IV funds were applied to the student account but were not processed in COD within the required time frame. Another two instances were noted where Title IV funds were applied to the student account but were not processed in COD at all. Responsible Individuals: Robert Hoover, Director of Financial Aid on behalf of the vacant place of Loan Coordinator position Corrective Action Plan: The financial aid office has reconciliation and exception report processes to identify and correct COD records promptly. Vacancies in Summer 2021, Fall 2021, and Spring 2022 posed challenges to reviewing and completing said process/reports. The office recently underwent system enhancement and utilization training during the Summer of 2022. These combined with the processes in place and having the Loan Coordinator (newly retitled Services Coordinator) will strengthen these areas further. Anticipated Completion Date: Ongoing
View Audit 31739
Finding 33826 (2022-002)
Material Weakness 2022
Clarke University of Dubuque, Iowa
IA
Special Tests & Provisions Questioned Costs Student Financial Aid
Finding 2022-002 Student Financial Assistance Program Cluster - Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2021/2022 P268K211430. Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance ...
Finding 2022-002 Student Financial Assistance Program Cluster - Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2021/2022 P268K211430. Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary: One instance was identified where the Return of Title IV calculation was not completed. Another instance was identified where the Return of Title IV calculation was completed using the incorrect withdrawal date. Additionally, one instance was identified where the Return of Title IV calculation was completed, but the funds were returned late. The University did not perform a Return of Title IV calculation for students who completed an interim course and then withdrew during the spring semester. The incorrect withdrawal date was used to calculate the amount of aid to be returned. Process to ensure that funds were submitted in a timely manner were not followed. Responsible Individuals: Robert Hoover, Director of Financial Aid and Kristin Harrington, Assistant Director of Financial Aid Corrective Action Plan: The Financial Aid office has undergone systems enhancement training during Summer 2022. Updating processes specific to the Return of Title IV Funds that will lend in the identification and processing timeline/steps associated with the complex process of identifying, calculating, and returning Title IV funds. After consultation with auditors, the FA Office will conduct calculations (as it relates to interim coursework) moving forward so that future issues, of this nature, will be avoided. Anticipated Completion Date: 10/21/2022
View Audit 31739
Corban University
OR
Reporting Questioned Costs Student Financial Aid
Enrollment Reporting to NSLDS Planned Corrective Action: Errors may have occurred due to transition in staff and insufficient processes related to identifying student non-attendance. Error reports from the National Student Clearinghouse are reviewed after every submission and errors are corrected. S...
Enrollment Reporting to NSLDS Planned Corrective Action: Errors may have occurred due to transition in staff and insufficient processes related to identifying student non-attendance. Error reports from the National Student Clearinghouse are reviewed after every submission and errors are corrected. Second, processes related to identifying students who have stopped attending classes were strengthened during the Fall 2022 semester. Person Responsible for Corrective Action Plan: Chris Vetter - Interim Provost Anticipated Date of Completion: December 30, 2022
View Audit 28940
Fisher College
MA
Student Financial Aid Reporting Matching / Level of Effort / Earmarking
Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing Number: 84.063 and 84.268 Award year:2022 Corrective Act...
Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing Number: 84.063 and 84.268 Award year:2022 Corrective Action Plan: To ensure complete and comprehensive National Student Loan Data System (NSLDS) reporting compliance as outlined in 34 CFR 685.309(b)(2) and in 2 CFR Part 200, Appendix XI Compliance Supplement, the College undertook a formal review of its NSLDS policies, processes and reporting procedures.- Our review acknowledges that areas in our current procedures could result in reporting inaccuracies, and we ascertain that these areas of our policies and procedures have now been formally updated to safeguard our future compliance. Changes and additions to current procedures will include a process of more timely reconciliation of monthly enrollment submissions, a more structured reconciliation of withdrawals and graduates, an annual review of the Department of Education's NSLDS Enrollment Reporting Guide, as well as an annual review/update of our internal policies and procedures. Additionally, the Director of Title IV Compliance will be responsible for enhanced bi-annual trainings of the College Registrar and of the Assistant Dean of Academic Services and Retention on the requirements and importance of NSLDS reporting. As these positions are key to data accuracy, NSLDS reporting functionality and our subsequent compliance with Federal regulations, it is paramount to note that whenever administrative turnover occurs, the new employees must be fully trained in the requirements of NSLDS reporting.
View Audit 29666
Finding 33710 (2022-003)
Significant Deficiency 2022
Tusculum University
TN
Student Financial Aid Reporting Significant Deficiency
2022-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Name of Contact Person Melissa White, Director of Financial Aid is responsible to upload d...
2022-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Name of Contact Person Melissa White, Director of Financial Aid is responsible to upload data to clearinghouse Corrective Action Planned During the audit, it was noted that Tusculum reported the incorrect date to NSLDS for the withdrawal date. Anthology reported the status date instead of the true withdrawal date. Therefore, if a student withdrew on January 1st but the status was not updated until January 4th. The report would pull January 4th instead of the true withdrawal date of January 1st. Tusculum University has since converted back to Colleague which pulls the true withdrawal date versus the status date. Colleague was the system used in the prior to Anthology that correctly reported withdrawal dates. With this conversion back, and the data exporting the true withdrawal date versus the status date, all student withdrawal dates should pull correctly. Anticipated Completion Date The University begun conversion back to Colleague in August 2022. The Majority of conversion from Anthology back to Colleague has been completed for this section to pull correctly as of March 2023.
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