Corrective Action Plans

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2022-001 National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend the University add a procedure to help detect any data entry errors. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in respon...
2022-001 National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend the University add a procedure to help detect any data entry errors. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Student Financial Aid investigated the issue and developed a solution. The University updated its policies and procedures and implemented the necessary training to ensure data entry errors are detected and corrected. Name of the contact person responsible for corrective action: Dave Meredith, Vice President for Enrollment Management Planned completion date for corrective action plan: September 30, 2022 If the U.S. Department of Education has questions regarding this plan, please call Dave Meredith, Vice President for Enrollment Management at 419-530-5704.
Cash Management Planned Corrective Action: As noted from review of previous audits, we do not typically have issues with cash management, as we carefully review student disbursement reports prior to drawing down funds from G5, as well as practice regular monthly reconciliations. Unfortunately, erro...
Cash Management Planned Corrective Action: As noted from review of previous audits, we do not typically have issues with cash management, as we carefully review student disbursement reports prior to drawing down funds from G5, as well as practice regular monthly reconciliations. Unfortunately, errors were made due to the cause that is described in this finding with the temporary reassignment of tasks. We have not had any noted issues in our G5 draws since February 2022, and we do not believe that this will be a reoccurring issue in the future. We will continue to train a back-up employee to assist the primary employee if she is again temporarily unavailable in the future. Person Responsible for Corrective Action Plan: Deborah O?Gwynn, Student Accounts Director Anticipated Date of Completion: Fall 2022
Finding 2022-006 Condition For one student out of seven tested, a student was awarded two direct plus loans which caused the student?s financial assistance received to be greater than the student?s cost of attendance. Corrective Action Plan Corrective Action Planned: We agree with this findi...
Finding 2022-006 Condition For one student out of seven tested, a student was awarded two direct plus loans which caused the student?s financial assistance received to be greater than the student?s cost of attendance. Corrective Action Plan Corrective Action Planned: We agree with this finding and are rectifying the issue. United Lutheran Seminary has retained a new Financial Aid Specialist who possesses the required knowledge and suitable skills for the position. Name(s) of Contact Person(s) Responsible for Corrective Action: Susie Kowalski, Director of Financial Aid. Anticipated Completion Date: Ms. Kowalski started with United Lutheran Seminary July 1, 2022.
View Audit 18555 Questioned Costs: $1
Finding 2022-005 Condition Federal Aid refunds were not calculated correctly for one student out of three tested and resulted in the Organization not refunding the correct amounts. This was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: We agree with this...
Finding 2022-005 Condition Federal Aid refunds were not calculated correctly for one student out of three tested and resulted in the Organization not refunding the correct amounts. This was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: We agree with this finding and are rectifying the issue. United Lutheran Seminary has retained a new Financial Aid Specialist who possesses the required knowledge and suitable skills for the position. Name(s) of Contact Person(s) Responsible for Corrective Action: Susie Kowalski, Director of Financial Aid. Anticipated Completion Date: Ms. Kowalski started with United Lutheran Seminary July 1, 2022.
View Audit 18555 Questioned Costs: $1
Finding 2022-004 Condition The Organization did not reconcile its SAS data file to its financial records for all 12 months of the fiscal year; however, the Organization did complete the annual reconciliation at the end of the fiscal year. Corrective Action Plan Corrective Action Planned: We ...
Finding 2022-004 Condition The Organization did not reconcile its SAS data file to its financial records for all 12 months of the fiscal year; however, the Organization did complete the annual reconciliation at the end of the fiscal year. Corrective Action Plan Corrective Action Planned: We agree with this finding and are rectifying the issue. United Lutheran Seminary has retained a new Financial Aid Specialist who possesses the required knowledge and suitable skills for the position. Name(s) of Contact Person(s) Responsible for Corrective Action: Susie Kowalski, Director of Financial Aid. Anticipated Completion Date: Ms. Kowalski started with United Lutheran Seminary July 1, 2022.
Finding 2022-003 Condition For six students out of nine tested, the change in student status was not reported to the NSLDS within 30 days or included in a response to a roster file within 60 days. However, the students were ultimately reported to the NSLDS. This sample was not statistically vali...
Finding 2022-003 Condition For six students out of nine tested, the change in student status was not reported to the NSLDS within 30 days or included in a response to a roster file within 60 days. However, the students were ultimately reported to the NSLDS. This sample was not statistically valid. Corrective Action Plan Corrective Action Planned: We agree with this finding and are rectifying the issue. United Lutheran Seminary has retained a new Financial Aid Specialist who possesses the required knowledge and suitable skills for the position. Name(s) of Contact Person(s) Responsible for Corrective Action: Susie Kowalski, Director of Financial Aid. Anticipated Completion Date: Ms. Kowalski started with United Lutheran Seminary July 1, 2022.
Finding 2022-002 Condition One roster file out of three tested was not completed and returned within the 15-day requirement to the NSLDS. This sample was not statistically valid. Corrective Action Plan Corrective Action Planned: We agree with this finding and are rectifying the issue. United...
Finding 2022-002 Condition One roster file out of three tested was not completed and returned within the 15-day requirement to the NSLDS. This sample was not statistically valid. Corrective Action Plan Corrective Action Planned: We agree with this finding and are rectifying the issue. United Lutheran Seminary has retained a new Financial Aid Specialist who possesses the required knowledge and suitable skills for the position. Name(s) of Contact Person(s) Responsible for Corrective Action: Susie Kowalski, Director of Financial Aid. Anticipated Completion Date: Ms. Kowalski started with United Lutheran Seminary July 1, 2022.
Finding 2022-001 Condition There was not an adequate system of controls in place that would have prevented or detected potential material noncompliance matters within the Activities Allowed or Unallowed, Eligibility and Special Tests and Provisions (related to Return of Title IV Funds, Enrollmen...
Finding 2022-001 Condition There was not an adequate system of controls in place that would have prevented or detected potential material noncompliance matters within the Activities Allowed or Unallowed, Eligibility and Special Tests and Provisions (related to Return of Title IV Funds, Enrollment Reporting and Federal Direct Loan Disbursements) compliance requirement areas. Corrective Action Plan Corrective Action Planned: We agree with this finding and are rectifying the issue. United Lutheran Seminary has retained a new Financial Aid Specialist who possesses the required knowledge and suitable skills for the position. Name(s) of Contact Person(s) Responsible for Corrective Action: Susie Kowalski, Director of Financial Aid. Anticipated Completion Date: Ms. Kowalski started with United Lutheran Seminary July 1, 2022.
Findings 2022-004 and 2021-001 Direct Loan Reconciliations Condition: For the fiscal year ending May 31, 2022, monthly Direct Loan Reconciliations were not performed for the months of June 2021 through September 2021. Views of Responsible Officials: The Academy does not disagree with this audit fi...
Findings 2022-004 and 2021-001 Direct Loan Reconciliations Condition: For the fiscal year ending May 31, 2022, monthly Direct Loan Reconciliations were not performed for the months of June 2021 through September 2021. Views of Responsible Officials: The Academy does not disagree with this audit finding. Corrective Action Plan: Direct Loan reconciliations a performed on a monthly basis by the Director of Financial Aid and a report is provided to the VP of Administration of Finance showing the tie out between G5 and COD. Responsible Party: Frances Hutchinson, Director of Financial Aid Anticipated Completion Date: This process was implemented in October 2021.
Finding 2022-003 Disbursements to or on Behalf of Students Condition: During testing of disbursements to or on behalf of students, 16 out of the 25 students selected for testing did not receive a written notification from the institution for the Fall of 2021 semester. Views of Responsible Official...
Finding 2022-003 Disbursements to or on Behalf of Students Condition: During testing of disbursements to or on behalf of students, 16 out of the 25 students selected for testing did not receive a written notification from the institution for the Fall of 2021 semester. Views of Responsible Officials: The Academy does not disagree with this audit finding. Corrective Action Plan: The Academy's student information system, Campus Cafe, provides online award letter notification to all students for review to approve and/or decline. Responsible Party: Frances Hutchinson, Director of Financial Aid Anticipated Completion Date: This process was implemented in Fall 2022.
Finding 2022-002 Internal Controls Condition: During testing of compliance requirements such as eligibility and verification testing, there was not documentation of a level of review to ensure the requirements were met and accurate. Views of Responsible Officials: The Academy does not disagree wit...
Finding 2022-002 Internal Controls Condition: During testing of compliance requirements such as eligibility and verification testing, there was not documentation of a level of review to ensure the requirements were met and accurate. Views of Responsible Officials: The Academy does not disagree with this audit finding. Corrective Action Plan: The Academy's Financial Aid Counselor will complete a checklist for eligibility and verification and the Director of Financial Aid will provide documented signoff once the checklist is reviewed for completeness and accuracy. Responsible Party: Frances Hutchinson, Director of Financial Aid Anticipated Completion Date: This process was implemented in November 2021 once Clifton Larson Allen started assisting the Academy.
Finding 2022-001 Fiscal Operations Report and Application to Participate (FISAP) Condition: Under Part II. Application to Participate for Award Year July 1, 2022 through June 30, 2023 Section E. Assessments and Expenditures, the undergraduate total tuition and fees for the award year July 1, 2020 t...
Finding 2022-001 Fiscal Operations Report and Application to Participate (FISAP) Condition: Under Part II. Application to Participate for Award Year July 1, 2022 through June 30, 2023 Section E. Assessments and Expenditures, the undergraduate total tuition and fees for the award year July 1, 2020 to June 30, 2021 was overreported by $380,731. Graduate total tuition and fees for the award year July 1, 2020 to June 30, 2021 was underreported by $28,122. Views of Responsible Officials: The Academy does not disagree with this audit finding. Corrective Action Plan: The Academy's Director of Financial Aid will prepare the FISAP and the VP of Administration and Finance will review and provide official signoff on the FISAP before it's submitted. Responsible Party: Frances Hutchinson, Director of Financial Aid Anticipated Completion Date: This process will be implemented with the submission of the FISAP for July 1, 2023 through June 30, 2024.
Finding 22689 (2022-005)
Significant Deficiency 2022
Marymount University administration acknowledges the findings from the 2021-2022 audit. Marymount administration takes the findings, which arose as part of the fiscal year 2021-2022 audit, very seriously and, following a root cause analysis, has put in place the following comprehensive corrective ac...
Marymount University administration acknowledges the findings from the 2021-2022 audit. Marymount administration takes the findings, which arose as part of the fiscal year 2021-2022 audit, very seriously and, following a root cause analysis, has put in place the following comprehensive corrective action plan: - Marymount University has experienced a turnover in the financial aid office from the Director down to the counselor position. Transitional issues have arisen from the turnover, including lack of continuity in office processes and lack of knowledgeable staff. - In late 2022, Marymount University contracted with Attain Partners, LLC, to provide interim management services in Financial Aid. After the turnover of personnel, this was necessary to fill the void created by the departure of the Director of Financial Aid and other staff. The Attain Partners consultants have provided the interim management services to assure compliance with Title IV regulations, including Return to Title IV Funds process. - Due to the turnover in the office, the calculations were not completed. Attain Partners has completed the reconstruction and COD updates. - Current R2T4 processes are in line with Title IV regulations. Attain Partners will assure timely processing going forward. - Attain Partners will be reviewing existing processes related to student financial aid. As an outcome of this review the processes and schedule will be fully documented and implemented as documented.
Finding 22688 (2022-004)
Significant Deficiency 2022
Marymount University followed the University grading policy when determining whether or not a student received an earned F grade in all of his/her courses. (See below for policy information). Marymount University?s grading policy states that an F grade is assigned for students who fail to meet cou...
Marymount University followed the University grading policy when determining whether or not a student received an earned F grade in all of his/her courses. (See below for policy information). Marymount University?s grading policy states that an F grade is assigned for students who fail to meet course objectives; such an F grade is by definition an earned F and not an unearned F as the student has completed the course but failed to meet standards. Marymount University instructors assign FA (Failure to Attend) grades for students who disappear, walk away, or otherwise fail to complete a course. For FA grades, last dates of attendance are assigned by instructors in the majority of cases. In the case of the students cited in the finding, Marymount followed its own grading policy when determining whether or not the failing grade received by the student was an earned F (completing the course but failing to meet course objectives) or an FA grade (failure to attend and did not complete the course). F grades would not result in Return to Title IV Funds calculations since they were considered earned. FA grades would result in Return to Title IV Funds calculations because they were considered unearned failing grades. Marymount University is not an attendance-taking institution according to Title IV standards, and individual instructors have control over their own attendance policies. Last dates of attendance as reported by these instructors are used in Return to Title IV Funds calculations; if a last date of attendance cannot be determined, the 50% point is used. Marymount University has the policy in place. However, Marymount University will review the language of the policy and revise the language to remove any ambiguities in the future. Marymount University Attendance Policy https://marymount.smartcatalogiq.com/en/2021-2022/catalog/marymount-university-catalog-2021-22/academic-information-and-policies/undergraduate-academic-information-and-policies/attendance/ Undergraduate Grading Policy https://marymount.smartcatalogiq.com/2021-2022/catalog/marymount-university-catalog-2021-22/academic-information-and-policies/undergraduate-academic-information-and-policies/evaluation-of-students/undergraduate-grading-policies/ Graduate Grading Policy https://marymount.smartcatalogiq.com/2021-2022/catalog/marymount-university-catalog-2021-22/academic-information-and-policies/graduate-academic-information-and-policies/evaluation-of-students/graduate-grading-policies/
Finding 22687 (2022-003)
Significant Deficiency 2022
Marymount University administration acknowledges the findings from the 2021-2022 UG Audit. Marymount administration takes the findings very seriously and, following a root cause analysis, has put in place the following comprehensive corrective action plan: ? Marymount University has experienced a tu...
Marymount University administration acknowledges the findings from the 2021-2022 UG Audit. Marymount administration takes the findings very seriously and, following a root cause analysis, has put in place the following comprehensive corrective action plan: ? Marymount University has experienced a turnover in the Office of Financial Aid from the Director down to the counselor position. Transitional issues have arisen from the turnover, including lack of continuity in office processes and lack of knowledgeable staff. ? In late 2022, Marymount University contracted with Attain Partners, LLC, to provide interim management services in Financial Aid. After the turnover of personnel, this was necessary to fill the void created by the departure of the Director of Financial Aid and other staff. The Attain Partners consultants have provided the interim management services to assure compliance with Title IV regulations, including Direct Loan reconciliation. ? Attain Partners has fully reconciled the 2021-2022 Federal Direct Loan funds and has put processes in place in conjunction with the Marymount University Financial Affairs Division to assure monthly and final reconciliation going forward. ? Attain Partners will be reviewing existing processes related to student financial aid. As an outcome of this review the processes and schedule will be fully documented and implemented as documented.
Finding 22682 (2022-001)
Significant Deficiency 2022
Finding 2022-001: Timely Enrollment Report The Institute failed to notify the National Student Loan Data System for three selected students' withdrawals within the required 60 days. However, it was properly determined for the students to have earned 100% of the Title IV funds. Corrective Action Pla...
Finding 2022-001: Timely Enrollment Report The Institute failed to notify the National Student Loan Data System for three selected students' withdrawals within the required 60 days. However, it was properly determined for the students to have earned 100% of the Title IV funds. Corrective Action Plan Management has immediately implemented the ad hoc reporting option, which includes the Associate Director of Registration and Student Records notifying the NSLDS of student withdrawals at time of withdrawal. This policy will ensure timely reporting of withdrawals and will be included in the standard procedure process for the withdrawal of a student. Contact Person Leanne Beaudoin Ryan Director of Research, Records and Registration lbeaudoinryan@erikson.edu Anticipated Completion Date February 2023
Finding 22679 (2022-004)
Significant Deficiency 2022
Student Financial Assistance Cluster ? Assistance Listing Number 84.268 Recommendation: We recommend the University review its policies and procedures around exit counseling to ensure students are receiving proper counseling and documentation is maintained of this process in the University?s student...
Student Financial Assistance Cluster ? Assistance Listing Number 84.268 Recommendation: We recommend the University review its policies and procedures around exit counseling to ensure students are receiving proper counseling and documentation is maintained of this process in the University?s student files. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This error also occurred during the transition period of the previous Financial Aid Director and winter graduates were forgotten to be notified. The Financial Aid Office has updated its procedures and have been in discussions with the IT Department to automate the process. Name(s) of the contact person(s) responsible for corrective action: Hannah Brown, Director of Financial Aid Planned completion date for corrective action plan: Complete.
Finding 22678 (2022-003)
Significant Deficiency 2022
2022-003 Student Financial Assistance Cluster ? Assistance Listing Number 84.268 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations. Explanatio...
2022-003 Student Financial Assistance Cluster ? Assistance Listing Number 84.268 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Monthly reconciliations have occurred in the Financial aid office, however, the sample selection occurred during the month when a transition in director occurred. The reconciliation was completed a month late. Reconciliations have now been improved by including other offices in the process and have been placed on a regular schedule. Name(s) of the contact person(s) responsible for corrective action: Hannah Brown, Director of Financial Aid Planned completion date for corrective action plan: Complete
Finding 22674 (2022-001)
Significant Deficiency 2022
2022-001 Student Financial Assistance Cluster ? Assistance Listing Numbers 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures to ensure accurate effective dates are reported in both the campus level and program level r...
2022-001 Student Financial Assistance Cluster ? Assistance Listing Numbers 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures to ensure accurate effective dates are reported in both the campus level and program level records submitted to the NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This was addressed in February 2023, the Registrar's office met with the Office of Financial Aid to determine what date on a student's withdraw application is the correct to Clearinghouse reporting. Name(s) of the contact person(s) responsible for corrective action: Bill Manley, Registrar Planned completion date for corrective action plan: Complete
Finding 22672 (2022-002)
Significant Deficiency 2022
2022-002 Student Financial Assistance Cluster ? Assistance Listing Numbers 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Part of this process should...
2022-002 Student Financial Assistance Cluster ? Assistance Listing Numbers 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Part of this process should include review of calculations by another member of the Financial Aid office. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This was corrected once identified in the FY21 single audit, however, due to timing of that audit, it was a repeat finding for 2022. Name(s) of the contact person(s) responsible for corrective action: Hannah Brown, Director of Financial Aid Planned completion date for corrective action plan: Completed May 2022
View Audit 22529 Questioned Costs: $1
FINDING: 2022-001 Return of Title IV Funds Federal Agency / Federal Program: U.S. Department of Education / Student Financial Assistance Cluster Subject: Special Tests and Provisions (N) CFDA Number: Federal Pell Program ? 84.063 The School agrees with the finding. Planned Corrective Actio...
FINDING: 2022-001 Return of Title IV Funds Federal Agency / Federal Program: U.S. Department of Education / Student Financial Assistance Cluster Subject: Special Tests and Provisions (N) CFDA Number: Federal Pell Program ? 84.063 The School agrees with the finding. Planned Corrective Action Plan: The School performed the RT24?s in a timely manner and then requested from its third party servicer to return the necessary funds. The third party servicer failed to return them. Upon discovery, the School terminated its relationship with the servicer. The School will update its policies and procedures to ensure timely returns. Responsible for corrective action: Galina Shumskaya Anticipated completion date: September 30, 2023
View Audit 18477 Questioned Costs: $1
FINDING 2022-002 ? Verification Condition Found: The information on the verification worksheet and tax transcript for Parents? AGI, Parents? Taxes Paid, Parent 1 and 2 Earned Income, and Parents? Military/Clergy Housing Allowance did not agree to the amounts reported on the ISIR for one of the twe...
FINDING 2022-002 ? Verification Condition Found: The information on the verification worksheet and tax transcript for Parents? AGI, Parents? Taxes Paid, Parent 1 and 2 Earned Income, and Parents? Military/Clergy Housing Allowance did not agree to the amounts reported on the ISIR for one of the twenty-five students sampled. Corrective Action Plan: The Financial Aid Office updated the income items and recalculated the EFC for the students in question. The amount of Pell the student was eligible to receive was calculated based on the new EFC. $300 was returned to the Department of Education in August 2022. Anticipated Completion Date: The corrective action was completed in August 2022. Contact Person: Samuel Tschetter, Director Student Affairs/Title IX Coordinator 816-322-0110 Ext. 1384
FINDING 2022-002 ? Verification Condition Found: The information on the verification worksheet and tax transcript for Parents? AGI, Parents? Taxes Paid, Parent 1 and 2 Earned Income, and Parents? Military/Clergy Housing Allowance did not agree to the amounts reported on the ISIR for one of the twe...
FINDING 2022-002 ? Verification Condition Found: The information on the verification worksheet and tax transcript for Parents? AGI, Parents? Taxes Paid, Parent 1 and 2 Earned Income, and Parents? Military/Clergy Housing Allowance did not agree to the amounts reported on the ISIR for one of the twenty-five students sampled. Corrective Action Plan: The Financial Aid Office updated the income items and recalculated the EFC for the students in question. The amount of Pell the student was eligible to receive was calculated based on the new EFC. $300 was returned to the Department of Education in August 2022. Anticipated Completion Date: The corrective action was completed in August 2022. Contact Person: Samuel Tschetter, Director Student Affairs/Title IX Coordinator 816-322-0110 Ext. 1384
Enrollment Reporting to National Student Loan Data System (NSLDS) Explanation: It was found that some students enrollment data were being reported incorrectly. It is not known if the error is coming from PowerCampus or NCS as majority of student records are correctly submitted. Planned Corrective ...
Enrollment Reporting to National Student Loan Data System (NSLDS) Explanation: It was found that some students enrollment data were being reported incorrectly. It is not known if the error is coming from PowerCampus or NCS as majority of student records are correctly submitted. Planned Corrective Action: The Office of Financial Aid will be working more closely with Registrar?s Office on the enrollment reporting submitted to the National Student Clearinghouse (NCS) each reporting cycle. Errors will be reviewed to determine why the error happened and how to correct the issue to prevent future errors. Comparisons will be done between our report and NSC and then with NSLDS. Person Responsible for Corrective Action Plan: Karen LaQuey and Dr. Wendy McNeeley Anticipated Date of Completion: Ongoing. Will do review for success December 2022 and then again in May 2023
Incorrect Modular Return of Title IV Funding Explanation: Students that were enrolled in summer modules and required a Return to Title IV (R2T4) calculation were being processed under the standard summer session calculation and not under modules. If a student was enrolled in more than one module,...
Incorrect Modular Return of Title IV Funding Explanation: Students that were enrolled in summer modules and required a Return to Title IV (R2T4) calculation were being processed under the standard summer session calculation and not under modules. If a student was enrolled in more than one module, we did not review the enrollment between the two modules to determine percentage of attendance and if R2T4 was required. Planned Corrective Action: Additional review steps are in place to review summer module enrollment and percentages. The Return to Title IV calendar will be set up differently inside Common Origination and Disbursement (COD) to allow for the module funding calculations. Person Responsible for Corrective Action Plan: Karen LaQuey Anticipated Date of Completion: September 30, 2022
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