Corrective Action Plans

Finding 547011 (2024-001)

None 2024

PR

Student Financial Aid Matching / Level of Effort / Earmarking

The University experimented numerous personal changes in the Register and Financial Aid Office, resulting complicated the continuity of established policies and processes. However, the University reviewed its processes and internal controls and established training for the Register and Financial Aid...

The University experimented numerous personal changes in the Register and Financial Aid Office, resulting complicated the continuity of established policies and processes. However, the University reviewed its processes and internal controls and established training for the Register and Financial Aid Office to ensure this report is submitted within the regularly timeframe. The results of these efforts will be effective during the 2025-2026 fiscal year

View Audit 351393

Finding 546965 (2024-003)

Significant Deficiency 2024

Avila University

MO

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

Enrollment information was not submitted accurately or within the required timeframe by the University. Personnel Responsible for Corrective Action: Margaret Herron, Registrar. Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2025. Corrective Action Plan: Managemen...

Enrollment information was not submitted accurately or within the required timeframe by the University. Personnel Responsible for Corrective Action: Margaret Herron, Registrar. Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2025. Corrective Action Plan: Management has provided training and the financial aid department will make regular updates to NSLDS on a monthly basis to ensure student information is reported accurately and timely.

View Audit 351349

Finding 546957 (2024-001)

None 2024

Santa Fe Community College

NM

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Santa Fe Community College respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the n...

Santa Fe Community College respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS III – Federal Award Findings 2024-001 – Compliance Requirements Over Reporting-Fiscal Operations Report and Application to Participate (FISAP) (Other Non-Compliance) Responsible Party: Nick Telles – Vice President of Finance and Jacob Pacheco – Chief Financial Officer and Financial Aid Director. Corrective Action Plan: Management concurs with this finding. Preliminary FISAP was entered into the Campus Based System (CBS) in order to perform built-in validation checks in CBA. The erroneous data was based on a Banner-generated FISAP report dated 8/21/2024. The final FISAP data was entered using a Banner reported generated 09/26/2024 but the field referenced within the finding were not entered when finalizing the data. Institutions are allowed to make corrections to the FISAP until December 15th each calendar year. Once identified, the corrections were submitted on 10/24/2024. Anticipated Completion Date: June 30, 2025 If there are any questions regarding this plan, please call Nick Telles at 505-428-1161 or email at nick.telles@sfcc.edu or Jacob Pacheco at 505-428-1814 or email at jacob.pacheco@sfcc.edu.

View Audit 351337

Finding 546954 (2024-002)

Significant Deficiency 2024

Furman University

SC

Questioned Costs Student Financial Aid Significant Deficiency

Federal Eligibility Recommendation: We recommend that during the financial aid package review, additional procedures are put in place to ensure that student awards are appropriately calculated. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action...

Federal Eligibility Recommendation: We recommend that during the financial aid package review, additional procedures are put in place to ensure that student awards are appropriately calculated. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The employee who committed the errors is no longer employed by Furman University. Based on federal regulations, citied in “Correcting Direct Subsidized Loan or Direct Unsubsidized Loan awarding errors” in Volume 8, Chapter 3 of the FSA Handbook: “If you discover that a student received Direct Subsidized Loan funds in excess of financial need after the student is no longer enrolled for the loan period, you are not required to take any action to eliminate the excess subsidized loan amount.” Furman University will continue to conduct regular training sessions for all financial aid counselors. These sessions focus on the latest federal and state regulations, including updates to Title IV guidelines, eligibility criteria, and documentation requirements. This ongoing training is crucial for maintaining our counselors' knowledge and effectiveness in managing financial aid processes. Furman University will perform an internal audit sample each month in conjunction with the completion of monthly reconciliations to ensure compliance with subsidized loans. Furthermore, all financial aid counselors are required to complete the “FSA Coach” training, an online resource provided by Federal Student Aid. This tool enhances their understanding of federal guidelines and best practices. To ensure future compliance, the Director of Financial Aid will conduct periodic internal audits. These audits will include a review of student files, application processes, and disbursement procedures to verify adherence to regulatory requirements. Additionally, the Director of Financial Aid will collaborate with a PowerFaids software consultant to explore the feasibility of generating specific reports that can monitor potential over awards of need-based aid. This proactive approach will help us identify and address any discrepancies promptly. Name(s) of the contact person(s) responsible for corrective action: Andrea Byrd Planned completion date for corrective action plan: 12/01/2024

View Audit 351333 Questioned Costs: $1

Finding 546953 (2024-001)

Significant Deficiency 2024

Furman University

SC

Student Financial Aid Reporting Significant Deficiency

NSLDS Reporting Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS within the required sixty-day time period. Explanation of disagreement with audit findin...

NSLDS Reporting Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS within the required sixty-day time period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Furman University added additional enrollment reporting dates in April and July to address the identified over 60-day gap. Specifically, we have incorporated two new reporting dates in April 2025 and July 2025. These dates are now part of our reporting schedule for the 2024-25 academic year and will continue to be included in the transmission schedule moving forward. Additionally, the University Registrar will provide the Senior Associate Director of Financial Aid with the annual enrollment reporting dates at the beginning of each academic year to ensure ongoing compliance. Name(s) of the contact person(s) responsible for corrective action: James Patton and Melissa Barnette Planned completion date for corrective action plan: 08/26/2024

View Audit 351333

Finding 546951 (2024-002)

Significant Deficiency 2024

Bunker Hill Community College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action Plan: Funds for the student referenced were transferred to COD on 5/4/2024, 2 days after disbursement. During this timeframe, there were significant communication errors between the US DOE, the SAIG mailbox and institutions including Bunker Hill Community College due to the impleme...

Corrective Action Plan: Funds for the student referenced were transferred to COD on 5/4/2024, 2 days after disbursement. During this timeframe, there were significant communication errors between the US DOE, the SAIG mailbox and institutions including Bunker Hill Community College due to the implementation of FAFSA simplification. The rejected file was found during monthly reconciliation and resolved on 6/3/2024. To prevent this type of error from happening again, Bunker Hill has moved to a bi-weekly review of the PRER Pell discrepancy report in Colleague. While we feel that this error is largely due to circumstances surrounding the challenges with FAFSA simplification, this additional bi-weekly review will prevent any possible reoccurrence of late reporting. Timeline for Implementation of Corrective Action Plan: Effective immediately Contact Person Jillian Glaze, Senior Director of Student Financial Services

View Audit 351324

Finding 546939 (2024-001)

Significant Deficiency 2024

Embry-Riddle Aeronautical University

FL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

Embry-Riddle Aeronautical University Corrective Action Plan Single Audit - Fiscal Year Ending 2024 Finding: 2024-001 Federal Program: Federal Direct Student Loans (ALN 84.268) Federal Pell Grant Program (ALN 84.063) Name(s) of the contact person(s) responsible for corrective action: • Julie Ferguson...

Embry-Riddle Aeronautical University Corrective Action Plan Single Audit - Fiscal Year Ending 2024 Finding: 2024-001 Federal Program: Federal Direct Student Loans (ALN 84.268) Federal Pell Grant Program (ALN 84.063) Name(s) of the contact person(s) responsible for corrective action: • Julie Ferguson, University Registrar • Edward Trombley, Registrar, Worldwide Campus • Ria Woods White, Senior Associate Registrar, Residential Campuses • Scott Johnson, Associate Registrar, University Registrar Office View of Responsible Officials: Registrar leadership agree with the audit finding and will implement additional review procedures to ensure that enrollment and graduate records are submitted to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Corrective Action Plan: Action Anticipated Completion Date Institute periodic internal reviews to ensure that the enrollment and graduation reporting process meet required standards. Ongoing Operationalize a duplicative review process for Worldwide enrollment and graduation report submissions. Ongoing

View Audit 351304

Finding 546936 (2024-006)

Material Weakness 2024

Urban College of Boston

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective a deficiency in the submission of enrollment data to the Clearinghouse. In April 2024 after t...

Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective a deficiency in the submission of enrollment data to the Clearinghouse. In April 2024 after the 2023 audit, we identified there were issues with how our enrollment reporting was being submitted to the Clearinghouse. Unfortunately, these 2023-2024 findings occurred prior to the implementation of new process and timing of our Enrollment reporting since these results of the 2022-2023 audit. The Registrar updated their process to ensure the reporting date parameters are being reported correctly and that the last date of attendance is pulled into the fields needing to be reported to the National Student Loan Data System (NSLDS) as the Effective Date. Enrollment reporting is being reported more frequently and is submitted at the start of each term, subsequently within the term, and at the end of the term to ensure reporting timelines are met and that the withdrawal date and effective date match for reporting purposes. Timeline for Implementation of Corrective Action Plan: Although categorized as a repeat finding, Urban College considers this year’s issue an extension of the original finding from the 2023 audit period. This is because the corrective action plan addressing the initial finding was not implemented until April 2024, after the conclusion of the 2023 audit. Furthermore, all the students involved in this year’s finding were enrolled before the corrective action plan was rolled out in April 2024. Contact Person: Waqas Mirza, Registrar: Waqas.Mirza@urbancollege.edu

View Audit 351293

Finding 546934 (2024-005)

Significant Deficiency 2024

Urban College of Boston

MA

Student Financial Aid Matching / Level of Effort / Earmarking

Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determine the errors are reflective of a knowledge gap in the established process for returning unearned funds for a withdrawn stu...

Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determine the errors are reflective of a knowledge gap in the established process for returning unearned funds for a withdrawn student. This was a process gap oversight. When Urban College of Boson (UCB) contracted with Global Financial Aid Services (Global FAS) effective for the 2023/2024 Award Year, the R2T4 return process is all done automated through a negative disbursement check register process. However, the funds that required Institutional Returns are a manual process and identified through a Refunds Due Report or as part of the students final Exit Packet Counseling documents. This report was missing as part of the workflow resulting in these students’ refunds being missed. The process has since been updated and the Director of Student Financial Services receives an automated Refunds Due Report (ineligible disbursement) every Monday. If there are students listed in the Refunds Due Report, this report is shared with the Business Office so funds can be returned based on amounts, funding type so they are processed timely. A secondary check point is also built into the process; If Urban has not returned the funds and 45 days from the students’ last date of attendance we will receive an automated notification from the Global Services system alerting us to the number of days we have left to make our returns. Since this issue was discovered the Director of Student Financial Services has gone back through all R2T4 student Exit Counseling packets to confirm that no other Institutional Returns were needed. No other issues were found. Timeline for Implementation of Corrective Action Plan: Although categorized as a repeat finding, Urban College considers this year’s issue an extension of the original finding from the 2023 audit period. This is because the corrective action plan addressing the initial finding was not implemented until April 2024, after the conclusion of the 2023 audit. Furthermore, all the students involved in this year’s finding were enrolled before the corrective action plan was rolled out in April 2024. Contact Person: Stacy Broadus, Director of Student Financial Services: Stacy.Broadus@urbancollege.edu

View Audit 351293

Finding 546932 (2024-004)

Significant Deficiency 2024

Urban College of Boston

MA

Questioned Costs Student Financial Aid

Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected student and the college’s policies and procedures, has determine the error was a result of an isolated event due to human error. This was an oversight on the part of the Director of Stud...

Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected student and the college’s policies and procedures, has determine the error was a result of an isolated event due to human error. This was an oversight on the part of the Director of Student Financial Services. When communicating with the Business Office on the amount of Pell funds to be returned for these students, the DSFS keyed in the wrong dollar amounts resulting in less funds being returned than should have been. Since this issue was discovered, our process has changed and to ensure the correct dollar amounts of returns are made, the DSFS receives an automated Refunds Due (ineligible disbursement) report each Monday morning and if students are listed based on R2T4 calculations, that report is then shared with our Business Office, so the exact dollars and funding sources are identified for returns. This prevents someone from needing to key in the amounts manually. The DSFS went back through all R2T4 packets to confirm that no other incorrect amounts were communicated so adjustments could be made if necessary. No other issues were found. Timeline for Implementation of Corrective Action Plan: Implementation of new processes effective April 1, 2024 Contact Person: Stacy Broadus, Director of Student Financial Services: Stacy.Broadus@urbancollege.edu

View Audit 351293 Questioned Costs: $1

Finding 546930 (2024-003)

Material Weakness 2024

Urban College of Boston

MA

Questioned Costs Student Financial Aid

Corrective Action The Urban College of Boston (UCB) agrees with this finding and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective of a lack of understanding of procedures involved in the return of uncashed checks. In April ...

Corrective Action The Urban College of Boston (UCB) agrees with this finding and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective of a lack of understanding of procedures involved in the return of uncashed checks. In April 2024 after the 2023 audit, we identified this as a missed practice in the Business Office procedures and because of the lack of understanding of the regulation, Business Office processes were created. Unfortunately, these 2023-2024 findings occurred prior to the implementation of this new process that was a result of the 2022-2023 audit. The Business Office leadership team reviews uncashed checks every 30 days as part of the ledger & billing reconciliation process to ensure these are addressed prior to the 240-day regulation. This process has been updated in the Business Office Cash Management operating procedure to ensure that UCB continues to meet the required timeline. Timeline for Implementation of Corrective Action Plan: Although categorized as a repeat finding, Urban College considers this year’s issue an extension of the original finding from the 2023 audit period. This is because the corrective action plan addressing the initial finding was not implemented until April 2024, after the conclusion of the 2023 audit. Furthermore, all the students involved in this year’s finding were enrolled before the corrective action plan was rolled out in April 2024. Contact Person: Stacy Broadus, Director of Student Financial Services: Stacy.Broadus@urbancollege.edu

View Audit 351293 Questioned Costs: $1

Finding 546928 (2024-002)

Significant Deficiency 2024

Urban College of Boston

MA

Student Financial Aid Cash Management Reporting

Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective of a lack of understanding of procedures involved in posting and reporting to COD. In April...

Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective of a lack of understanding of procedures involved in posting and reporting to COD. In April 2024 after the 2023 audit, we identified this as a gap in the Business Office process to ensure that dates disbursed matched the COD system. This process was rectified, and the business office staff was coached and trained. Unfortunately, these 2023-2024 findings occurred prior to the implementation and coaching of these new processes. Urban College of Boston (UCB) has contracted with Global Financial Aid Services (Global FAS) effective for the 2023/2024 Award Year. Global FAS provides UCB with a monthly reconciliation report through our shared Secured File Transfer Protocol site (SFTP)and notifies us when one is ready to be reviewed. Once the file is received, the Business Office will conduct a secondary reconciliation using the Global FAS report. The Business Office will review the students ledger/billing and compare information with COD to ensure all disbursement information matches according to regulation. Urban College conducted a full reconstruction of COD dates to Ledger posting dates and ensured that all dates for this auditing period and current funding year disbursements are accurate. Urban College has also moved to a once-a-week disbursement schedule which will structure our reporting from our SIS system to COD and assist in the accuracy of our data review. Global Financial Services has been conducting a quarterly testing of our disbursement records to also ensure the accuracy of data. The Director of Financial Aid and Chief Finance Officer will continue to review procedures and update according to regulation and policy changes so potential gaps are discovered proactively. Timeline for Implementation of Corrective Action Plan: Although categorized as a repeat finding, Urban College considers this year’s issue an extension of the original finding from the 2023 audit period. This is because the corrective action plan addressing the initial finding was not implemented until April 2024, after the conclusion of the 2023 audit. Furthermore, all the students involved in this year’s finding were enrolled before the corrective action plan was rolled out in April 2024. Contact Person: Stacy Broadus, Director of Student Financial Services: Stacy.Broadus@urbancollege.edu

View Audit 351293

Finding 546925 (2024-001)

Material Weakness 2024

Urban College of Boston

MA

Student Financial Aid

Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective of weak procedures and lack of knowledge from our Business office of Title IV requirements in...

Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective of weak procedures and lack of knowledge from our Business office of Title IV requirements involving the handling of Title IV credit balances. In April 2024 after the 2023 audit, we identified weaknesses in Title IV credit balance process. It was also discovered during the 2023 audit review that not all our Business Office employees understood the federal regulation on Title IV refunds and the 14-day rule. When processes were reviewed and updated, the financial aid and business office staff went through coaching and training. Unfortunately, these 2023-2024 credit balance findings occurred prior to the implementation of these new processes from the results of the 2022-2023 audit. Urban College of Boston (UCB) has contracted with Global Financial Aid Services (Global FAS) effective for the 2023/2024 Award Year. Process changes include Global FAS providing UCB with a daily check register report of all student disbursements. Through the Disbursement process, UCB must first process all check registers, reconcile student billing, and identify and process student credit balances before funds can be drawn down from the Common Origination and Disbursement System (COD). The UCB Business Office commits to processing check registers within 7 business days and providing the Cash Monitoring report to Global FAS so funds can be released and deposited into the Federal Funds Account. The Business Office also conducts a weekly credit balance review in the event adjustments were made to a student’s account that may have created a credit. These updated processes will ensure student refunds are processed within the 14-day federal regulation. The Director of Student Financial Services is also conducting a twice of month Balance Report review to identify any credit balances on students accounts to determine if they are within or outside of the 14 days and reporting back to the Chief Finance Officer if any discrepancies are discovered. Timeline for Implementation of Corrective Action Plan: Although categorized as a repeat finding, Urban College considers this year’s issue an extension of the original finding from the 2023 audit period. This is because the corrective action plan addressing the initial finding was not implemented until April 2024, after the conclusion of the 2023 audit. Furthermore, all the students involved in this year’s finding were enrolled before the corrective action plan was rolled out in April 2024. Contact Person: Stacy Broadus, Director of Student Financial Services: Stacy.Broadus@urbancollege.edu

View Audit 351293

Finding 546915 (2024-005)

Material Weakness 2024

The University of Chicago

IL

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

Finding No. 2024-005 Failure to Notify Recipients of Federal Direct Loan and Federal Pell Grant Disbursements ALNs: 84.063, 84.268 Program: Student Financial Assistance Cluster Corrective Action: The University created an automated process to send financial aid notifications on a regular basis. Comp...

Finding No. 2024-005 Failure to Notify Recipients of Federal Direct Loan and Federal Pell Grant Disbursements ALNs: 84.063, 84.268 Program: Student Financial Assistance Cluster Corrective Action: The University created an automated process to send financial aid notifications on a regular basis. Completed: January 31, 2024 Contact Person: Amanda Fijal

View Audit 351271

Finding 546912 (2024-004)

Material Weakness 2024

The University of Chicago

IL

Questioned Costs Student Financial Aid Allowable Costs / Cost Principles § 200.303

Finding No. 2024-004 Failure to Properly Complete Required Verification Procedures ALNs: 84.007, 84.033, 84.063, 84.268 Program: Student Financial Assistance Cluster Corrective Action: Additional training will be provided to staff. Implementation Date: June 30, 2025 Contact Person: Amanda Fijal

View Audit 351271 Questioned Costs: $1

Finding 546911 (2024-003)

Material Weakness 2024

The University of Chicago

IL

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

Finding No. 2024-003 Failure to Determine Eligibility in Accordance with SFA Regulations ALNs: 84.007, 84.033, 84.063, 84.268 Program: Student Financial Assistance Cluster Corrective Action: Additional training will be provided to staff. Implementation Date: June 30, 2025 Contact Person: Amanda Fija...

Finding No. 2024-003 Failure to Determine Eligibility in Accordance with SFA Regulations ALNs: 84.007, 84.033, 84.063, 84.268 Program: Student Financial Assistance Cluster Corrective Action: Additional training will be provided to staff. Implementation Date: June 30, 2025 Contact Person: Amanda Fijal

View Audit 351271 Questioned Costs: $1

Finding 544783 (2024-005)

Significant Deficiency 2024

Chestnut Hill College

PA

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

2024-005 Federal Supplemental Educational Opportunity Grants; Federal Pell Grant Program; Federal Direct Student Loans; Teacher Education Assistance for College and Higher Education Grants - Assistance Listing No. 84.007, 84.063, 84.268, 84.379 Recommendation: The College should develop and implemen...

2024-005 Federal Supplemental Educational Opportunity Grants; Federal Pell Grant Program; Federal Direct Student Loans; Teacher Education Assistance for College and Higher Education Grants - Assistance Listing No. 84.007, 84.063, 84.268, 84.379 Recommendation: The College should develop and implement an approved written information security program and verify there is a risk management section that describes how the College is identifying, assessing and communicating risks. In addition, there should be a description on the evaluation of safeguard sufficiency in mitigating risks. The information security program should also include the following: • IT Security Policy • Acceptable Use Policy • Incident Response Policy • Data Classification Policies • Vendor Management Policy • Patch Management Policy • Data Disposal Policy • Risk Assessment Policy • Logical Access and User Access Review Policies • Evidence of Review by CIO/CISO and responsibility of program Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will develop and implement an information security program to verify our risk management efforts. This plan will identify how we are identifying, assessing and communicating risk. Name(s) of the contact person(s) responsible for corrective action: Scott Seidman, Director of IT Planned completion date for corrective action plan: June 30, 2025

View Audit 351264

Finding 544781 (2024-004)

Significant Deficiency 2024

Chestnut Hill College

PA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

2024-004 Federal Pell Grant Program; Federal Direct Student Loans -Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the C...

2024-004 Federal Pell Grant Program; Federal Direct Student Loans -Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the College review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of the Registrar is reviewing its policies and procedures to ensure that all data is captured and reported in a timely manner as required by federal regulations. A software issue that caused inaccurate data to be reported has been identified and resolved by a software update. The Office of the Registrar is working with the Office of Information Technology to test the accuracy of the updated software. Name(s) of the contact person(s) responsible for corrective action: Micheal Reig, Registrar Planned completion date for corrective action plan: June 30, 2025

View Audit 351264

Finding 544777 (2024-003)

Significant Deficiency 2024

Chestnut Hill College

PA

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

2024-003 Federal Supplemental Educational Opportunity Grants; Federal Pell Grant Program; Federal Direct Student Loans; Teacher Education Assistance for College and Higher Education Grants- Assistance Listing Nos: 84.007, 84.063, 84.268, 84.379 Recommendation: We recommend the College review the R2T...

2024-003 Federal Supplemental Educational Opportunity Grants; Federal Pell Grant Program; Federal Direct Student Loans; Teacher Education Assistance for College and Higher Education Grants- Assistance Listing Nos: 84.007, 84.063, 84.268, 84.379 Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into the R2T4 calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Financial Aid will work with the Registrar to ensure that we receive the academic calendar in a timely manner. Once received, breaks will be verified by the Assistant Director of Financial Aid and then confirmed by the Director of Financial Aid. Name(s) of the contact person(s) responsible for corrective action: Jossie Johnson, Director of Financial Aid Planned completion date for corrective action plan: June 30, 2025

View Audit 351264 Questioned Costs: $1

Finding 544776 (2024-002)

Significant Deficiency 2024

Chestnut Hill College

PA

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

2024-002 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding:...

2024-002 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: While the Office of Financial Aid has revamped how it manages exit notices and has made an improvement, our report has failed to pick up students that went from undergraduate to graduate in consecutive semesters. We will develop and implement a new report to ensure that this population is picked and exit notices are sent in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Jossie Johnson, Director of Financial Aid, and Micheal Reig, Registrar Planned completion date for corrective action plan: June 30, 2025

View Audit 351264

Finding 544706 (2024-002)

Significant Deficiency 2024

Tabor College, Inc.

KS

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Criteria or Specific Requirement - The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the chang...

Criteria or Specific Requirement - The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition - We noted discrepancies in the data reported in NSLDS compared to the data in the College’s records. Cause - The College’s processes and controls did not ensure that the effective dates were properly reported to NSLDS. Effect or potential effect - The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Questioned costs - None Context - During our testing, we noted for three out of eleven students tested, the program begin date per the institution did not match the student's effective date reported to NSLDS. In addition, we noted for one out of eleven students tested the notification was not made within 60 days. Sampling was not a statistically valid sample. Identification as a repeat finding, if applicable - 2023-003 Recommendation - We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials and planned corrective actions - Management concurs with the findings and recommendations. See separate report for planned corrective actions. Views of Responsible Officials and Corrective Action Plan – Management concurs with the findings and recommendation. Responsible personnel will review current guidance available from the Department of Education website and develop internal procedures to ensure timely compliance. This plan will include personnel and responsibility redundancy to account for employee absences or turnover, and a continuous review of available guidance to ensure the College stays current with any changes to this guidance. Additionally, monthly reconciliations have been added to the College’s procedures to ensure any errors are caught in a timely manner. Individual Responsible – Caleb Loss, Vice President for Business and Finance Anticipated Completion Date – April 2025

View Audit 351214

Finding 544690 (2024-004)

Significant Deficiency 2024

Tusculum University

TN

Subrecipient Monitoring Student Financial Aid Significant Deficiency

2024-004 Significant Deficiency: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) (Repeat Finding: 2023-002) Name of Contact Person Casey Reagan, Registrar, and Chris Summey, Head of our IT Department, are the designated employees in cha...

2024-004 Significant Deficiency: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) (Repeat Finding: 2023-002) Name of Contact Person Casey Reagan, Registrar, and Chris Summey, Head of our IT Department, are the designated employees in charge of overseeing the GLBA Policy Corrective Action Planned During the audit, it was noted that the University’s Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University during the 2024 year. A new policy was put into place during June 2024. During the 2023-24 academic year, the policy was being updated to be compliant. Due to this finding in 2022-23, the FSA Cyber Compliance Team reached out to Tusculum and Tusculum provided the Corrective Action Plan and new policy. On August 1st, 2024, Tusculum received word that the CAP acceptably addressed the GLBA finding. Anticipated Completion Date 08/1/2024

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Finding 544689 (2024-005)

Significant Deficiency 2024

Tusculum University

TN

Student Financial Aid Reporting Significant Deficiency

2024-005 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) (Repeat finding of 2022-001 and 2023-003) Name of Contact Person Casey Reagan, Registrar, an...

2024-005 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) (Repeat finding of 2022-001 and 2023-003) Name of Contact Person Casey Reagan, Registrar, and Melissa White, Director of Financial Aid, are responsible for enrollment reporting. Casey Regan for the data and Melissa White for uploading the report to clearinghouse. Corrective Action Planned During the audit, it was noted that Due to lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. While the university did implement changes from the prior year, including randomly sampling students, after this finding and looking into the issue that was occurring, we found three more issues with our clearinghouse data. The first issue was our graduation file that was sent to clearinghouse was not being processed and being rejected. We were unaware of the rejection of the records. We have worked with a clearinghouse representative and created a new way of pulling the graduate students report to ensure that their status is properly reported and sent to NSLDS. The second issue was that some student files were individually being rejected and thus not processing fully through. To correct this issue, we are watching the rejected clearinghouse files for individual students and are manually reporting their statuses if we cannot get the file to accept. The final and third issue was that students who were unofficially or administratively withdrawn were pulling the wrong date and thus the status was showing the wrong dates for the occurrence. To fix this, financial aid and the registrar are working in tandem to ensure that the correct date that the actual unofficial withdrawal or administrative withdrawal is correct. If necessary, we will manually certify these students as well. Anticipated Completion Date 03/01/2025

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Finding 544688 (2024-003)

Significant Deficiency 2024

Tusculum University

TN

Student Financial Aid Reporting Significant Deficiency

2024-003 Significant Deficiency: Federal Work-Study (FWS) (U.S. Department of Education, Federal Work-Study Program, ALN #84.033) Name of Contact Person Melissa White, Director of Financial Aid, is responsible for ensuring that Federal Work Study students are not working during class time. Correct...

2024-003 Significant Deficiency: Federal Work-Study (FWS) (U.S. Department of Education, Federal Work-Study Program, ALN #84.033) Name of Contact Person Melissa White, Director of Financial Aid, is responsible for ensuring that Federal Work Study students are not working during class time. Corrective Action Planned During the audit, it was noted that Tusculum failed to compare hours submitted as worked hours to student class schedules. In order to ensure that this does not occur again, all supervisors have been reminded of the requirement that students do not work during seat time. Regular reminders sent to supervisors and regular trainings are offered to supervisors to remind supervisors of the Federal Work Study Guidelines. In addition, as each timesheet is submitted, financial aid shall check to ensure no violations have occurred. Anticipated Completion Date 10/15/2024

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Finding 544687 (2024-002)

Significant Deficiency 2024

Tusculum University

TN

Student Financial Aid Reporting Significant Deficiency

2024-002 Significant Deficiency: Federal Work-Study (FWS) Underpayment (U.S. Department of Education, Federal Work-Study Program, ALN #84.033) Name of Contact Person Melissa White, Director of Financial Aid, is responsible for ensuring that Federal Work Study students are properly paid for hours w...

2024-002 Significant Deficiency: Federal Work-Study (FWS) Underpayment (U.S. Department of Education, Federal Work-Study Program, ALN #84.033) Name of Contact Person Melissa White, Director of Financial Aid, is responsible for ensuring that Federal Work Study students are properly paid for hours worked. Corrective Action Planned During the audit, it was noted that Tusculum errantly miscalculated hours worked and wages payable results in student receiving fewer Title IV funds than what they may have earned or be eligible for. Once found, the missing hours were added to the next payroll and the students were paid. To ensure this error does not occur again in the future, financial aid has created a secondary check system that includes keeping an additional excel that confirms that each timesheet has been paid for each student and that their full hours worked have been paid. We have also reinforced with supervisors the urgency of making sure timesheets are submitted in a timely manner so that the error does not occur again as the timesheets in question were late timesheets. Additional training for supervisors and constant reminders to supervisors are also ongoing. Anticipated Completion Date 10/15/2024

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