Corrective Action Plans

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Program: AL 93.658 – Foster Care Title IV-E – Allowability Corrective Action Plan: The spreadsheet has been corrected and a journal entry will be completed to correct the amount billed to IV-E. Contact: Bryan Gilliland Anticipated Completion Date: February 28, 2026
Program: AL 93.658 – Foster Care Title IV-E – Allowability Corrective Action Plan: The spreadsheet has been corrected and a journal entry will be completed to correct the amount billed to IV-E. Contact: Bryan Gilliland Anticipated Completion Date: February 28, 2026
Program: AL 93.658 – Foster Care Title IV-E – Allowability Corrective Action Plan: The Agency will evaluate and develop new processes to review and ensure that attendance records match billing documents, authorizations, and claims. An evaluation of the Provider Portal will be completed to identify e...
Program: AL 93.658 – Foster Care Title IV-E – Allowability Corrective Action Plan: The Agency will evaluate and develop new processes to review and ensure that attendance records match billing documents, authorizations, and claims. An evaluation of the Provider Portal will be completed to identify enhancements to this area. The Agency will develop a new fraud prevention process for the Resource Development team to enhance controls over attendance, billing, and the auditing of provider claims, and to ensure compliance. A Provider Probation process will be implemented to address identified billing concerns. Contact: Nicole Vint Anticipated Completion Date: September 30, 2026
Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.007, 84.063, 84.268 Award year: 2025 The Registrar’s Office will perform a mandatory “Missing SSN Report” that picks up missing and invalid SSNs before every ...
Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.007, 84.063, 84.268 Award year: 2025 The Registrar’s Office will perform a mandatory “Missing SSN Report” that picks up missing and invalid SSNs before every enrollment data submission to the National Student Clearinghouse (“NSC”). The Registrar will send the Financial Aid Office a list of students with missing SSNs and Financial Aid will verify if students in the report have a FAFSA on file. If there is a FAFSA on file for a student, Financial Aid will update the SSN in the Banner system and send an email confirmation to the Registrar to confirm all records on the report have been reviewed and/or updated. The next enrollment file submitted to the NSC will include the students with the correct data. Furthermore, the Registrar Office will send a written communication to the Provost/Vice President for Academic Affairs verifying that all student records sent the National Student Clearing House has a SSN number prior to any reporting deadline. This communication will be kept on file and available for review for the next audit period. As an additional step, when Financial Aid staff load initially unmatched ISIRs to active Westfield State student records, Banner is now set to automatically populate the student record with the social security number from the matched FAFSA. The goal is to reduce the number of missing social security numbers pulled by the Registrar when they run the “Missing SSN report.” Timeline for Implementation of Corrective Action Plan: Above corrections were implemented in November 2025. Contact Person: Monique Lopez, Registrar and Simone Backstedt, Director, Financial Aid
FINDING 2025-002 Name of Responsible Individual: Mary Mercer, Director Student Financial Services Corrective Action: Issue: The current refund report used to monitor Title IV refunds has limitations that affected the completeness of data reviewed. Reports rely on manual batch postings, which can del...
FINDING 2025-002 Name of Responsible Individual: Mary Mercer, Director Student Financial Services Corrective Action: Issue: The current refund report used to monitor Title IV refunds has limitations that affected the completeness of data reviewed. Reports rely on manual batch postings, which can delay or omit certain transactions at the time of report generation. This created gaps in monitoring and potential human error. Action Step Responsible Party Timeline Transition to new system – Implement refund reporting to reduce manual errors and improve completeness. Student Financial Services & IT (if needed) Full adoption by Academic Year 2026–2027 Staff training – Provide comprehensive training to Student Financial Services staff on new system processes, reporting, and controls for Title-IV refunding. Ellucian Consultant & Student Financial Services When training session is scheduled through first report in 2026-2027 Interim verification controls – Conduct weekly reconciliation of batch postings and verifications that all Title IV refunds are captured until the new system is fully operational. Student Financial Services & Controller’s Office Immediate until system adoption Validation & reconciliation process – Establish a formal process within the new system to ensure all refunds are accurately captured and reported. Student Financial Services By first full report in 2026–2027
FINDING 2025-001 Name of Responsible Individual: Kasi Turner Corrective Action: To prevent future occurrences of missing campus‑level student enrollment reporting, both the University Registrar and Assistant Registrar will participate in the upcoming NSClearinghouse Academy on Thursday, March 26. Th...
FINDING 2025-001 Name of Responsible Individual: Kasi Turner Corrective Action: To prevent future occurrences of missing campus‑level student enrollment reporting, both the University Registrar and Assistant Registrar will participate in the upcoming NSClearinghouse Academy on Thursday, March 26. This session will provide a refresher on enrollment compliance reporting requirements and offer opportunities to connect with peers and Clearinghouse staff to discuss best practices. Additionally, I will begin collaborating with the MU Database Administrator, Mary Hupp, to compile and review all monthly enrollment reports prior to submission to the National Student Clearinghouse. As part of this strengthened workflow, we will implement a two‑person sign‑off to ensure that both the data extraction and the TXT file mapping are jointly reviewed and verified before transmission. This added step ensures a second review of both the database and the TXT file before transmission, strengthening accuracy,and reducing the likelihood of future omissions. Before the next reporting cycle, the Registrar’s Office will also review and update the current enrollment reporting process documentation in collaboration with Mary Hupp to ensure that all steps, and system validation points are clearly defined and consistently followed. Anticipated Completion Date: April 15, 2026
Finding: 2025-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033 Program Name: Student Financial Assistance Cluster Finding Summary: Institutions that implement an affirmative confirmation process (as described in 34 CFR 668.165 (a)(6)(...
Finding: 2025-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033 Program Name: Student Financial Assistance Cluster Finding Summary: Institutions that implement an affirmative confirmation process (as described in 34 CFR 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than seven days after, crediting the student’s account and must give the student 30 days (instead of 14) to cancel all or part of the loan. Responsible Individuals: Frankie Everett, Director, Financial Aid Corrective Action Plan: The College implemented a new ERP system in the current year that caused delays in notifying students of their loan disbursements. PowerFAIDS allows documenting the email sent to students in the Communication Log, but a box has to be checked when the email batch is sent. This step was inadvertently missed in several batches so we cannot confirm the email was sent. The Department is working to automate the emails with a college-hired consultant. In the meantime, the Financial Aid Operations Coordinator (Jessica Jones) is double-checking that disbursement emails are going out each week. Anticipated Completion Date: June 2026
Finding: 2025-001 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.063, and 84.268 Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for accurate report...
Finding: 2025-001 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.063, and 84.268 Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. The support provided by RCC for the students’ last date of attendance did not agree to the students’ withdrawal that had been submitted to NSLDS. Responsible Individuals: Danielle Crouch, Registrar and Analisa Gifford, Assistant Registrar Corrective Action Plan: During the 2023-2024 academic year, we were utilizing an outdated, homegrown Student Information System (SIS). A previously unidentified flaw in the system’s programming logic caused incorrect withdrawal dates to be populated in the National Student Clearinghouse (NSC) report. For the 2024-2025 academic year, we have transitioned to Jenzabar One, an industry-recognized SIS that includes built-in Enrollment Reporting functionality. To ensure accurate reporting moving forward, we are conducting audits of withdrawal dates at the end of each term. With the implementation of this new system and enhanced audit processes, this issue will be fully mitigated. Rogue Community College has implemented corrective actions to strengthen internal controls and ensure the accurate reporting of student enrollment statuses to the National Student Loan Data System (NSLDS). The College now utilizes withdrawal reports to systematically identify students who have withdrawn from all enrolled courses. These reports are reviewed to verify each student’s official withdrawal date prior to submission to NSLDS. For students who receive non-passing grades, the College reviews and reports the last date of attendance, when applicable, to ensure accurate determination of the student’s withdrawal date. As additional internal control, the College conducts term-end audits of withdrawal dates and last dates of attendance to confirm that enrollment status changes have been reported accurately and in accordance with federal requirements. Any discrepancies identified through this review process are corrected promptly. Additionally, the College utilizes graduation reports to verify that students who have completed all program requirements within their declared major are appropriately reported to NSLDS with an enrollment status of Graduated. Through these enhanced monitoring and verification procedures, Rogue Community College is confident that enrollment status changes are reported accurately and in compliance with the requirements outlined in 34 CFR 690.83(b)(2) and 34 CFR 685.309. Anticipated Completion Date: October 2025
The District acknowledges that deficiencies in internal controls over the Return to Title IV calculation process resulted in inaccurate calculations. The District has reviewed the identified calculations and corrected all errors. Return to Title IV policies and procedures will be updated and a stand...
The District acknowledges that deficiencies in internal controls over the Return to Title IV calculation process resulted in inaccurate calculations. The District has reviewed the identified calculations and corrected all errors. Return to Title IV policies and procedures will be updated and a standard process is to be completed for every calculation. The District will implement a mandatory secondary review of all Return to Title IV calculations prior to processing returns or post-withdrawal disbursements.
Finding - Special Reporting: Fiscal Operations Report and Application to Participate (FISAP) - Federal Work Study Program, Assistance Listing Number 84.033, Federal Supplemental Educational Opportunity Grants Program, Assistance Listing Number 84.007; June 30, 2025 Award Year; U.S. Department of Edu...
Finding - Special Reporting: Fiscal Operations Report and Application to Participate (FISAP) - Federal Work Study Program, Assistance Listing Number 84.033, Federal Supplemental Educational Opportunity Grants Program, Assistance Listing Number 84.007; June 30, 2025 Award Year; U.S. Department of Education Condition The graduate enrollment figure at Section D line 7(b) included an additional 51 students on the FISAP submitted on September 29, 2025. Corrective Actions During our compliance audit it came to light that New England Institute of Technology accidentally overstated the quantity of graduate students on our FISAP that was filed originally on September 29, 2025, by 51 students. We immediately revised the FISAP to make the correction and filed it with the Department of Education on December 9, 2025. New England Institute of Technology will implement a process to compare the system-generated enrollment reports to enrollment data to ensure enrollment information this is reported on the FISAP is accurate. Responsible Official: Denise Brindle, Financial Aid Director Completion Date: December 2025
FISAP Reporting Planned Corrective Action: At the time of preparation of the FISAP report by the Financial Aid Office, electronic database reports used for preparation will be archived and attached to the report. The report will be reviewed the Vice President of Enrollment Management and the Vice Pr...
FISAP Reporting Planned Corrective Action: At the time of preparation of the FISAP report by the Financial Aid Office, electronic database reports used for preparation will be archived and attached to the report. The report will be reviewed the Vice President of Enrollment Management and the Vice President for Finance and Operations/CFO. Both reviewers will be provided the detailed reports that agree to the data reported. The review will consist of ensuring that the data on the database source, PowerFAIDS, is accurate and agrees with the reported data. Reviewer will run directly from the PowerFAIDS system a report consistent with the time frame of the FISAP and determine that the report agrees with the report attached to the FISAP submitted for review. Person Responsible for Corrective Action Plan: Ms. Monique Rickenbaker, Director of Financial Aid Mr. Yohannis Job, VP for Enrollment Management Dr. Sharron T. Burnett, VP for Finance and Operations/CFO Anticipated Date of Completion: June 30, 2026
Management Views and Corrective Action Plans 2025-001 - Untimely submissions of Accurate Student Enrollment Change to the National Student Loan Data System (NSLDS) Point of Contact – Jennifer Spiegel Goldberg, University Registrar, (646-592-6275) Management agrees with the current year’s finding and...
Management Views and Corrective Action Plans 2025-001 - Untimely submissions of Accurate Student Enrollment Change to the National Student Loan Data System (NSLDS) Point of Contact – Jennifer Spiegel Goldberg, University Registrar, (646-592-6275) Management agrees with the current year’s finding and recommendation to review its policies and controls for accurate and timely enrollment reporting by establishing a process to ensure that all required program and campus level status changes are reported to NSLDS and are reported within the required 60-day timeframe. Yeshiva University’s dual curriculum, multi-college undergraduate system, as well as some graduate programs allow students changes during enrollment that can result in extraneous degree records no longer linked to the student’s enrolled program. This circumstance and finding occurred because a graduation application was mistakenly applied to an extraneous record and carried through to conferred degree, which the NSC reporting system could not detect. A script has been in place since January 13, 2026, to run overnight to detect “orphan” degree records and ensure that only records that match current enrollment are available removing the potential for this to occur moving forward. The student identified during the audit as requiring remedy has been remedied in NSLDS as of November 19, 2025.
Finding 2025-001: Special Tests and Provisions - NSLDS Reporting (Significant Deficiency) U.S. Department of Education – Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Loan Program (84.268) View of Responsible Officials and Planned Corrective Action: With res...
Finding 2025-001: Special Tests and Provisions - NSLDS Reporting (Significant Deficiency) U.S. Department of Education – Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Loan Program (84.268) View of Responsible Officials and Planned Corrective Action: With respect to the findings relating to the timeliness of enrollment reporting, the University agrees with this finding and will take appropriate actions to improve processes to ensure enrollment status records are updated timely in the NSLDS at both the Campus-Level and Program-Level. Corrective Plan: • Reporting Calendar for All Branch Campuses o Ensure reporting calendar accommodates each branch campus at the University • Timely Enrollment Status Updates - Branch Campuses o Ensure completion is entered in SIS prior to the submission of the last enrollment file submitted for that term • Tracking Students Completing Outside of Original Cohort o Early completion o Late completion • Reporting Status Changes Outside the Standard Reporting Calendar o Process developed to report these students individually Name of Contact Person(s) Responsible for the Plan: Michael Lewis, Registrar Michael.lewis5@marist.edu Anticipated Completion Date: April 30, 2026
The College will ensure the accuracy of reports sent to NSLDS by making changes to their staffing structure and roles surrounding student leave of absences and withdrawals. The College hired a single administrator who assists students through the process of requesting a leave of absence or a withdra...
The College will ensure the accuracy of reports sent to NSLDS by making changes to their staffing structure and roles surrounding student leave of absences and withdrawals. The College hired a single administrator who assists students through the process of requesting a leave of absence or a withdrawal and processes all leaves, making the system more efficient. The Office of Financial Aid will continue to process Return to Title IV calculations immediately when notified about a Title IV recipient’s leave of absence or withdrawal.
Condition: The College did not send out the post-disbursement email notifications to a group of students. Planned Corrective Action: While the University has documented procedures in place for the disbursement of federal funds and required post-disbursement notifications to students, the finding ide...
Condition: The College did not send out the post-disbursement email notifications to a group of students. Planned Corrective Action: While the University has documented procedures in place for the disbursement of federal funds and required post-disbursement notifications to students, the finding identified related to only students who received both a Federal PLUS loan and a Federal Direct Loan during 2025. University did not properly send a post-disbursement notification to 117 out of 247 students who received both a federal PLUS loan as well as a Federal Direct Loan on a specific date during fiscal year 2024-2025. The University will adjust its internal processes to ensure all students who receive federal loans are sent post-disbursement email notifications by performing a review of the IT system and working toward fully automated notification settings to ensure all students are captured in the post-disbursement notification process. Contact person responsible for corrective action: Leah Alderink, Director of Student Financial Aid Anticipated Completion Date: Immediately
Action Plan - These errors were the result of a new student information system. As part of the implementation process, CIP codes were incorrectly migrated over from our legacy system to the new system (Colleague). This resulted in program enrollment status errors. Corrective Actions Completed: The R...
Action Plan - These errors were the result of a new student information system. As part of the implementation process, CIP codes were incorrectly migrated over from our legacy system to the new system (Colleague). This resulted in program enrollment status errors. Corrective Actions Completed: The Registrar's Office conducted a comprehensive review of all active program CIP codes and corrected all identified discrepancies within the student information system. The Registrar's Office is coordinating with Student Financial Services to verify that the 22 sampled students' enrollment and program statuses are accurately reflected in NSLDS. Corrective Actions in Progress: The Registrar's Office is obtaining direct NSLDS access to ensure the office responsible for enrollment reporting can independently review and validate reported data. Access is expected to be finalized by February 27th, 2026. Preventative Controls: Beginning Spring 2026, the Registrar's Office will implement a recurring end-of-term ntrol review. A sample of 12 students will be selected each semester to verify that enrollment status, program status, and CIP code reporting are accurate between the student information system and NSLDS. Results of this review will be documented and retained, and any discrepancies will be corrected prior to the subsequent enrollment submission. The Registrar believes these corrective measures address the root cause of the finding and strengthen internal controls to ensure ongoing compliance with federal reporting requirements. Responsible Official: Danielle Jeffress, University Registrar Estimated Completion Date: May 30, 2026
The College implemented additional procedures to allow earlier detection of fraud.
The College implemented additional procedures to allow earlier detection of fraud.
The College will perform the mass processing for COD reporting on a more frequent basis to ensure reporting is timely.
The College will perform the mass processing for COD reporting on a more frequent basis to ensure reporting is timely.
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Report training has been implemented and will continue on an ongoing basis to ensure compliance. We will implement periodic spot checks to prevent this issue from recurring and to ensure that all s...
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Report training has been implemented and will continue on an ongoing basis to ensure compliance. We will implement periodic spot checks to prevent this issue from recurring and to ensure that all students are properly enrolled each semester. Person Responsible for Corrective Action Plan: Registrar, Elena Majerowicz Anticipated Date of Completion: Already Implemented
Late Return of Title IV Funds Calculations Planned Corrective Action: We have implemented a document processing system in collaboration with our third-party administrator and the Student Accounts Office to ensure that funds required to be returned as part of the R2T4 process are processed on time. P...
Late Return of Title IV Funds Calculations Planned Corrective Action: We have implemented a document processing system in collaboration with our third-party administrator and the Student Accounts Office to ensure that funds required to be returned as part of the R2T4 process are processed on time. Person Responsible for Corrective Action Plan: Giselle Atenco, Director of Financial Aid Anticipated Date of Completion: Already Implemented
Need Analysis Planned Corrective Action: System-generated notifications have been implemented within our student information system to flag any academic year changes or required reviews. In addition, a periodic review process of student award packages has been established to ensure funds are awarded...
Need Analysis Planned Corrective Action: System-generated notifications have been implemented within our student information system to flag any academic year changes or required reviews. In addition, a periodic review process of student award packages has been established to ensure funds are awarded accurately and in accordance with applicable awards. Person Responsible for Corrective Action Plan: Giselle Atenco, Director of Financial Aid Anticipated Date of Completion: Already Implemented
Views of Responsible Officials and Planned Corrective Actions – While the Financial Aid Office does have two personnel reviewing each R2T4 calculation, the same was not done with the online calendars setup in COD. The Director will now review each online calendar before they are utilized. The Office...
Views of Responsible Officials and Planned Corrective Actions – While the Financial Aid Office does have two personnel reviewing each R2T4 calculation, the same was not done with the online calendars setup in COD. The Director will now review each online calendar before they are utilized. The Office of Financial Aid performed a review of the population of 672 students, noting an incorrect amount of funds was returned to the Department of Education for 32 of those students. The College has corrected and sent back the additional funds that the students were not eligible to receive.
Views of Responsible Officials and Planned Corrective Actions– The National Student Clearinghouse (NSC) Graduation Status submission calendar will be updated to reflect the necessary reporting timeline. NSC graduation status submission reports will be completed after verification of graduation requi...
Views of Responsible Officials and Planned Corrective Actions– The National Student Clearinghouse (NSC) Graduation Status submission calendar will be updated to reflect the necessary reporting timeline. NSC graduation status submission reports will be completed after verification of graduation requirements and credentialing are completed in Jenzabar by the Registrar's Office. Submission of graduation status to NSC will occur after each academic session and semester, to capture both traditional and non-traditional conferrals.
Student Financial Aid Cluster – National Student Loan Data System (NSLDS) Reporting Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations....
Student Financial Aid Cluster – National Student Loan Data System (NSLDS) Reporting Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have reviewed and updated our documentation, as needed; we have worked with our vendor to locate one source of errors and have corrected those issues in our database; we have started a two-person check on our enrollment and graduation uploads. Name(s) of the contact person(s) responsible for corrective action: Kelly Rowett-James Planned completion date for corrective action plan: We have completed the documentation review and the work with the vendor. We have started our two-person check on enrollment uploads and will continue to do so going forward; our first graduation upload will be done in May and we will start our two-person check for that type of transmission with that upload. If the U.S. Department of Education has questions regarding this plan, please call Jennifer Gallagher at 410-778-7765.
Eligibility Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.033, 84.268, 84.007 Recommendation: We recommend the University review its procedures to ensure that title IV funds is awarded correctly. Explanation of disagreement with audit finding: There is no disagreement with...
Eligibility Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.033, 84.268, 84.007 Recommendation: We recommend the University review its procedures to ensure that title IV funds is awarded correctly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pell Grant awards are reviewed prior to each disbursement. SCU has strengthened this control to ensure award amounts are adjusted to accurately reflect each student’s enrollment intensity at the time of disbursement. This review is documented and completed by the Director of Financial Aid before funds are released to ensure compliance with federal requirements. Name(s) of the contact person(s) responsible for corrective action: Laney Morales, Director of Financial Aid Planned completion date for corrective action plan: 12/1/2025
Return of Title IV (R2T4) Returning of Funds Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.033, 84.268, 84.007 Recommendation: We recommend the University review its procedures to ensure that title IV funds required to be returned are done within 45 days after the date of ...
Return of Title IV (R2T4) Returning of Funds Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.033, 84.268, 84.007 Recommendation: We recommend the University review its procedures to ensure that title IV funds required to be returned are done within 45 days after the date of the institution's determination that the student withdrew. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The existing Return of Title IV (R2T4) process was evaluated, and an additional oversight control was implemented to ensure timely returns of funds. All R2T4 calculations are reviewed weekly by the Assistant Director of Financial Aid. During this standing review, the return process is initiated through Jenzabar Financial Aid and confirmed on Common Origination and Disbursement (COD). This control provides documented oversight and ensures returns are completed within required timeframes, mitigating the risk of delays or batch processing errors. Name(s) of the contact person(s) responsible for corrective action: Janeth Chaidez, Assistant Director of Financial Aid. Planned completion date for corrective action plan: 12/1/2025
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