Corrective Action Plans

Finding 1176820 (2025-001)

Material Weakness 2025

ID

Student Financial Aid Reporting Significant Deficiency

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Perkins Loan Program– Assistance Listing No. 84.038 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal ...

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Perkins Loan Program– Assistance Listing No. 84.038 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants– Assistance Listing No. 84.379 Nursing Student Loans – Assistance Listing No. 93.364 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the short time the Financial Aid Office has had direct oversight of this process, we have substantially reduced the number of incidents. Enrollment Reporting is a top priority. Like our colleagues at other Idaho institutions, we are striving to eliminate all issues with enrollment reporting. Enrollment reports will continue to be submitted monthly. The data is reviewed at various intervals during the process by Registrar and Financial Aid staff, and the reviews are documented. Corrections and updates are provided and submitted as required. Procedures have been updated to reflect all changes and validations. Additional focus will be on the reports that overlap semesters. Timelines will be reviewed and adjusted as determined necessary Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Soo Lee Bruce-Smith, Travis Osburn, Kim Tuschhoff, and John Bender Planned completion date for corrective action plan: Immediate Implementation

View Audit 390663

Finding 1176726 (2025-001)

Material Weakness 2025

Pennsylvania College of Art & Design

PA

Student Financial Aid Reporting Significant Deficiency

Pennsylvania College of Art & Design Management’s Corrective Action Plan 6/30/25 Finding: Tuition revenue reported on the FISAP did not agree to the final audited general ledger due to timing of preparation and lack of documented reconciliation. Management Response and Corrective Action Plan: Manage...

Pennsylvania College of Art & Design Management’s Corrective Action Plan 6/30/25 Finding: Tuition revenue reported on the FISAP did not agree to the final audited general ledger due to timing of preparation and lack of documented reconciliation. Management Response and Corrective Action Plan: Management concurs with the finding. During the fiscal year, the Director of Financial Aid prepared the FISAP using tuition data obtained from the Bursar’s office in early September in order to meet the October 1 filing deadline. At that time, not all year-end adjusting journal entries had been recorded by the Controller, and a formal reconciliation of the FISAP tuition amount to the final general ledger had not been performed. To remediate this issue and strengthen internal controls over federal reporting, the College has implemented the following corrective actions: Formal Reconciliation Requirement Effective immediately, all financial data reported on the FISAP will be reconciled to the final general ledger balances after year-end adjusting entries are posted. Defined Roles and Review Process The Director of Financial Aid will prepare the FISAP using tuition revenue from the Controller-approved general ledger. The Controller will prepare and document a reconciliation between: FISAP tuition revenue General ledger tuition revenue The Chief Financial Officer will review and sign off on the reconciliation prior to FISAP submission. Responsible Officials: Controller (reconciliation), Director of Financial Aid (FISAP preparation), CFO (final review) Implementation Date: Effective for the June 30, 2026 reporting cycle.

View Audit 390636

Finding 1176678 (2025-002)

Material Weakness 2025

Thiel College

PA

Student Financial Aid

Finding 2025-002: Enrollment Reporting Condition: The change in student status for 1 of the 25 students tested was not reported to the National Student Loan Data Systems (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, this student was ultimately reported to...

Finding 2025-002: Enrollment Reporting Condition: The change in student status for 1 of the 25 students tested was not reported to the National Student Loan Data Systems (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, this student was ultimately reported to the NSLDS. The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audit Guide Corrective Action Plan: The College will closely review submissions to the National Clearing House to alleviate duplicate submissions that override previously submitted data. The College is committed to complete and accurate enrollment data submissions to the National Student Clearinghouse and ultimately to the National Student Loan Data System. Responsible Persons: Kim Peters, Director of Financial Aid and Debbie Schreiber, Registrar Anticipated Completion Date: Immediately

View Audit 390545

Finding 1176629 (2025-001)

Material Weakness 2025

Brooklyn Law School

NY

Student Financial Aid Subrecipient Monitoring Reporting

Brooklyn Law School Single Audit Corrective Action Plan For the Year Ending June 30, 2025 Section III - Federal Awards Findings and Questioned Costs Finding 2025-001: Significant Deficiency - NSLDS Enrollment Reporting Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of a...

Brooklyn Law School Single Audit Corrective Action Plan For the Year Ending June 30, 2025 Section III - Federal Awards Findings and Questioned Costs Finding 2025-001: Significant Deficiency - NSLDS Enrollment Reporting Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary of the Department of Education (Secretary), institutions must update all information included in the report and return the report to the Secretary: (I) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless the institution expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: The Law School did not notify the National Student Loan Data System (NSLDS) in a timely manner for 23 students with status changes in our sample of 25 students. For 2 out of 25 students selected in the sample, the effective date that was reported to the NSLDS did not match the date that the student changed status. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The Law School's controls surrounding the reporting of students’ statuses and status effective dates to the NSLDS did not appropriately ensure the information was submitted accurately or timely. Effect: The accuracy of the Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendation: We recommend that the Law School review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the Law School to ensure accurate and timely reporting. Management Response: Management agrees with the finding, The Director of Financial Aid and the Registrar will implement procedures and controls in fiscal 2026 to ensure accurate and timely updating of the enrollment reports to NSLDS. Anticipated Completion Date: June 30, 2026 Responsible Person: John K. Zhang, Vice President for Finance and Board Treasurer (718)-780-7503 - john.zhang@brooklaw.edu

View Audit 390480

Finding 1176607 (2025-001)

Material Weakness 2025

Allegheny College

PA

Student Financial Aid Reporting Significant Deficiency

Finding 2025-001 The College concurs with the audit finding that students who withdrew at the conclusion of the fall 2024 semester were not reported to the National Student Loan Data System (NSLDS) within the required 60-day reporting timeframe. This occurred as a result of two primary factors: (1) ...

Finding 2025-001 The College concurs with the audit finding that students who withdrew at the conclusion of the fall 2024 semester were not reported to the National Student Loan Data System (NSLDS) within the required 60-day reporting timeframe. This occurred as a result of two primary factors: (1) the enrollment reporting schedule with the National Student Clearinghouse was outdated, and (2) the 60-day reporting requirement was not clearly defined within Allegheny’s internal processes. Allegheny recognizes the importance of timely and accurate reporting of students’ enrollment status to NSLDS. Enrollment rosters and updated enrollment statuses are regularly reported to NSLDS to ensure that changes affecting loan repayment obligations and in-school deferment eligibility are accurately reflected within the Department of Education’s records. The College is committed to strengthening its procedures to ensure continued compliance with federal reporting requirements. The College will continue to adhere to NSLDS reporting processes and required timelines. Through enhanced collaboration among the Financial Aid, Registrar’s, and Provost’s Offices, Allegheny will fully align and formalize enrollment reporting procedures. The College will review, verify, and update reporting schedules to ensure accuracy and compliance with applicable requirements. Specifically, the College will annually review its enrollment reporting schedule with the National Student Clearinghouse to ensure that enrollment data is transmitted to the National Student Loan Data System (NSLDS) at least once every 60 calendar days, in accordance with federal reporting requirements. For students who notify the College of their intent to leave at the upcoming conclusion of a semester, the College will report the student as enrolled on the final enrollment report for that term and will then manually update the student's enrollment status to withdrawn within a few days of the report’s submission, rather than waiting for the next scheduled enrollment transmission, to ensure timely and accurate reporting. Allegheny College will implement quarterly review of processes established to ensure compliance. This proactive approach will ensure ongoing compliance with federal regulations. In addition, Allegheny College is developing a secondary review process for each enrollment report submission to identify students with recent or pending enrollment status changes. This review will serve as a quality control check to ensure that students whose enrollment status has changed since the prior reporting period are accurately identified and updated, thereby strengthening oversight and ensuring timely and compliant reporting to NSLDS.

View Audit 390423

Finding 1176602 (2025-001)

Material Weakness 2025

City University of Seattle

WA

Student Financial Aid

Background During the audit, it was identified that the University did not report all required program-level record elements to the National Student Loan Data System (NSLDS). Cause The root cause of the issue was a gap in our data entry and reporting processes: • Prior to January 1 2025, majors and ...

Background During the audit, it was identified that the University did not report all required program-level record elements to the National Student Loan Data System (NSLDS). Cause The root cause of the issue was a gap in our data entry and reporting processes: • Prior to January 1 2025, majors and program-level data for domestic students were entered by the domestic enrollment team. With the transition of responsibilities to the Registrar’s Office, controls were fully aligned to ensure program-level elements were consistently captured and transmitted. Corrective Action Plan The University has taken and will continue to take the following corrective actions: 1. Process Realignment o Responsibility for capturing and validating program-level record elements has been formally assigned to the Registrar’s Office. 2. System Enhancements o Validation reports have been developed to flag missing or inconsistent program-level data prior to NSLDS submission. 3. Follow-Up Monitoring o Quarterly monitoring ensures proactive identification and correction of any missing program-level enrollment data prior to submitting data to NSLDS. Conclusion The University is committed to ensuring full compliance with NSLDS enrollment reporting requirements. We believe the corrective measures outlined above will prevent recurrence of incomplete program-level reporting and strengthen the reliability of our enrollment submissions. Sincerely, Christopher Bryan CFO

View Audit 390422

Finding 1176568 (2025-007)

Material Weakness 2025

Johnson C. Smith University

NC

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

Corrective Action Plan: To address the deficiencies identified in Finding 2025-008, the University has implemented and continues to strengthen a Registrar-led corrective action framework focused on improving the accuracy, timeliness, and oversight of Campus-Level and Program-Level enrollment reporti...

Corrective Action Plan: To address the deficiencies identified in Finding 2025-008, the University has implemented and continues to strengthen a Registrar-led corrective action framework focused on improving the accuracy, timeliness, and oversight of Campus-Level and Program-Level enrollment reporting to the National Student Loan Data System (NSLDS). Primary Control Enhancements. The University has engaged Strata Information Group (SIG) to support validation and configuration of enrollment reporting functionality within Ellucian Colleague. This engagement assists the Registrar’s Office in ensuring that enrollment status changes, credential completions, and program-level data are transmitted accurately through established reporting processes. Responsibility for enrollment reporting remains with the Office of the Registrar, with SIG serving in a technical advisory capacity. The Office of the Registrar will establish a structured enrollment reporting cadence, including submission of enrollment files on a bimonthly basis. This reporting schedule will ensure timely identification and reporting of enrollment status changes in compliance with federal requirements and reduce reliance on ad hoc or event-driven reporting. Supporting Controls and Training. To further strengthen upstream data integrity, the Registrar’s Office will implement enrollment governance controls, including restricting late graduation applications and limiting major declarations to designated academic periods. These controls reduce late-cycle data changes that previously contributed to reporting inconsistencies. Monitoring and Quality Assurance. The Office of the Registrar has institutionalized a formal quality assurance calendar requiring enrollment reporting reviews at least twice per semester. These reviews validate the accuracy and timeliness of Campus-Level and Program-Level enrollment data reported to the National Student Clearinghouse (NSC) and, by extension, NSLDS. As part of this monitoring framework, the Registrar’s Office will conduct periodic sampling of reported enrollment records to confirm compliance with reporting timelines and verify the effectiveness of enrollment reporting controls. Sustained Oversight. Any discrepancies identified through quality assurance reviews will be documented, corrected, and evaluated to inform process refinement and prevent recurrence. To support reconciliation and data validation, the Registrar’s Office will meet monthly with the Office of Data Analytics to compare enrollment data within Ellucian Colleague to downstream reporting outputs. Anticipated Completion Date: June 2026

View Audit 390365

Finding 1176566 (2025-006)

Material Weakness 2025

Johnson C. Smith University

NC

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

Corrective Action Plan: To address the deficiencies identified in Finding 2025-006, The Offices of Student Accounts and Financial Aid offices (“the Offices”) will improve coordination and communication regarding the timing of fund transfers and refund disbursements. The Offices have established a sc...

Corrective Action Plan: To address the deficiencies identified in Finding 2025-006, The Offices of Student Accounts and Financial Aid offices (“the Offices”) will improve coordination and communication regarding the timing of fund transfers and refund disbursements. The Offices have established a schedule to begin the refund process 10 calendar days of the credit balance creation date to ensure compliance with the 14-day federal requirement. A written processing calendar has been established to track key deadlines and responsibilities. These actions establish preventive controls to ensure all Title IV credit balances are refunded within the federally required timeframe and to prevent recurrence. Ongoing monitoring of this process will ensure the University issues Title IV refunds within 14 days of the credit balance being applied to the student’s account. Anticipated Completion Date: December 2026

View Audit 390365

Finding 1176563 (2025-005)

Material Weakness 2025

Johnson C. Smith University

NC

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

Corrective Action Plan: To address the deficiencies identified in Finding 2025-005, the University has implemented and continues to strengthen a comprehensive corrective action framework focused on automating Return of Title IV (R2T4) processing, clarifying cross-functional responsibilities, enforci...

Corrective Action Plan: To address the deficiencies identified in Finding 2025-005, the University has implemented and continues to strengthen a comprehensive corrective action framework focused on automating Return of Title IV (R2T4) processing, clarifying cross-functional responsibilities, enforcing withdrawal data integrity, and institutionalizing quality assurance and supervisory oversight. Primary Control Enhancements. Ellucian Colleague has been configured to automate R2T4 calculations and prevent post-withdrawal disbursements without documented authorization, supported by system-generated audit trails. Supporting Controls and Training. Controls governing withdrawal determination have been strengthened, including required reporting of last date of attendance as a part of grade submission and faculty training to support accurate withdrawal data. This requirement strengthens the integrity of withdrawal data, supports accurate determination of official and unofficial withdrawal dates, and ensures that R2T4 calculations are based on verified enrollment activity. The University has clarified and formalized cross-functional responsibilities related to withdrawal determination and R2T4 processing. Controls now ensure structured communication between academic units, the Office of the Registrar, and the Office of Financial Aid, with defined ownership for initiating, calculating, reviewing, and completing R2T4 determinations. Monitoring and Quality Assurance. To ensure accuracy and timeliness, the University has implemented a secondary review process for all R2T4 calculations. Initial calculations completed in Ellucian Colleague are independently validated using the Return of Title IV calculation tools within the Common Origination and Disbursement (COD) system. This secondary calculation serves as a quality control measure prior to final processing and fund return. In addition, R2T4 activity is subject to periodic quality assurance reviews, including monitoring of calculation timeliness, authorization documentation, and fund return deadlines. Sustained Oversight. Any discrepancies identified by QA reviews are documented, corrected, and reviewed to inform process improvements and staff training. Supervisory oversight is in place to ensure compliance with federal timelines and calculation requirements. Anticipated Completion Date: August 2026

View Audit 390365

Finding 1176560 (2025-004)

Material Weakness 2025

Johnson C. Smith University

NC

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

Corrective Action Plan: To address the deficiencies identified in Finding 2025-004, the University has implemented and continues to enhance corrective actions focused on automating loan disbursement notifications, standardizing notification content and timing, strengthening documentation and audit t...

Corrective Action Plan: To address the deficiencies identified in Finding 2025-004, the University has implemented and continues to enhance corrective actions focused on automating loan disbursement notifications, standardizing notification content and timing, strengthening documentation and audit trails, and institutionalizing quality assurance oversight to ensure sustained compliance with federal notification requirements. Primary Control Enhancements. Loan disbursement notifications to the student for Subsidized, Unsubsidized, and Graduate PLUS Loans are now system-generated through Ellucian Colleague, providing automated delivery and a documented audit trail. Notifications are issued upon disbursement processing and delivered through system-supported modalities, including electronic communication and student portal updates. Ellucian Colleague retains a system-generated audit trail documenting the timing and content of each notification, strengthening the University’s ability to demonstrate compliance with federal requirements. This system-based approach eliminates reliance on third-party notification tools previously used and brings direct control of notification sequencing, content, and documentation within the University’s financial aid infrastructure. Supporting Controls and Training. The University has revised the Parent PLUS Loan notification process to ensure that required disbursement information—including the date, amount, and type of loan—is provided directly within the notification communication. While Parent PLUS notifications currently require initiation through a controlled manual process, procedures have been amended to ensure timely issuance, content accuracy, and supervisory oversight during this interim period. The University is actively working with the Ellucian Colleague implementation team to further automate Parent PLUS Loan disbursement notifications and eliminate manual triggering. Until full automation is achieved, documented procedures and quality assurance reviews will serve as compensating controls to ensure compliance with notification timing and content requirements. Monitoring and Quality Assurance. The University established and maintains a formal quality assurance framework to monitor loan disbursement notifications. A quality assurance calendar requires reviews at least twice per semester to confirm that notifications are issued within required regulatory timeframes, include all required elements, and are sent to the appropriate recipient (student or parent). As part of ongoing monitoring, the University has conducted multiple quality assurance reviews of loan disbursement notifications. These reviews have demonstrated improved compliance with notification timing and content requirements while also identifying isolated system sequencing issues that were promptly addressed through configuration updates and enhanced scheduling controls within Ellucian Colleague. Sustained Oversight. Any discrepancies identified through quality assurance reviews are documented, corrected, and evaluated to inform process refinement, system configuration, and staff training. Anticipated Completion Date: September 2026

View Audit 390365

Finding 1176559 (2025-003)

Material Weakness 2025

Johnson C. Smith University

NC

Student Financial Aid Internal Control / Segregation of Duties

Corrective Action Plan: To address the deficiency identified in Finding 2025-003, the University has implemented and is continuing to formalize corrective actions focused on strengthening award notification sequencing, automating required communications, and ensuring a verifiable audit trail prior t...

Corrective Action Plan: To address the deficiency identified in Finding 2025-003, the University has implemented and is continuing to formalize corrective actions focused on strengthening award notification sequencing, automating required communications, and ensuring a verifiable audit trail prior to the disbursement of Title IV funds. Primary Control Enhancements. With the assistance of Financial Aid Services (FAS), Ellucian Colleague has been configured to automate award notification generation upon completion of student packaging, creating a system-generated audit trail that documents notification timing relative to disbursement. This automation ensures that award notifications are issued prior to disbursement activity and creates a system-generated audit trail documenting the timing and issuance of the notification. Supporting Controls and Training. Financial Aid staff receive ongoing system and compliance training to reinforce proper sequencing of notifications and disbursements. Monitoring and Quality Assurance. Routine quality assurance reviews confirm that award notifications are issued and documented prior to disbursement, with exceptions documented and corrected. Sustained Oversight. Any exceptions identified will be reviewed, documented, and corrected to ensure sustained compliance. Anticipated Completion Date: June 2026

View Audit 390365

Finding 1176555 (2025-002)

Material Weakness 2025

Johnson C. Smith University

NC

Student Financial Aid Reporting Internal Control / Segregation of Duties

Corrective Action Plan: To address the deficiencies identified in Finding 2025-002, the University has implemented and is continuing to formalize a comprehensive corrective action strategy focused on strengthening disbursement scheduling, improving system integration, institutionalizing reconciliati...

Corrective Action Plan: To address the deficiencies identified in Finding 2025-002, the University has implemented and is continuing to formalize a comprehensive corrective action strategy focused on strengthening disbursement scheduling, improving system integration, institutionalizing reconciliation and quality assurance processes, and enhancing cross-functional oversight of COD reporting. Primary Control Enhancements. A standardized disbursement and reporting calendar has been established, and system integration between Ellucian Colleague and Jenzabar has been strengthened to improve consistency of cost-of-attendance and disbursement data transmitted to COD. For the 2025–2026 academic year, the Office of Financial Aid and the Office of Student Accounts are disbursing Title IV aid on the second and fourth Tuesday of each month. This schedule has been jointly approved and will continue to be followed by both departments to ensure consistency between disbursement activity and COD reporting. Supporting Controls and Training. Staff participate in targeted training related to COD reporting and cash management through NASFAA and FSA to reinforce knowledge of reporting timelines and requirements. Monitoring and Quality Assurance. A formal financial aid compliance calendar has been developed and institutionalized, outlining required quality assurance (QA) reviews by month, identifying responsible departments, and requiring documented supervisory sign-off. Reviews of COD reporting timelines are conducted twice per semester, and any discrepancies identified are documented, reviewed, and resolved in a timely manner. A systematic monthly reconciliation process has been instituted and is maintained involving the Office of Financial Aid, the Office of Student Accounts, and Budgets & Grants Accounting to ensure consistency across internal systems and COD reporting. Sustained Oversight. Any discrepancies identified through reconciliation are documented, communicated to relevant departments, and resolved, with formal supervisory sign-off required from the Assistant Director of Financial Aid and the Director of Budgets & Grants Accounting. In addition, Financial Aid maintains standing bi-weekly coordination meetings with Student Accounts and Business Office staff to support ongoing alignment related to Title IV disbursement activity and COD reporting timelines. Anticipated Completion Date: June 2026

View Audit 390365

Finding 1176553 (2025-001)

Material Weakness 2025

Johnson C. Smith University

NC

Student Financial Aid Matching / Level of Effort / Earmarking

Corrective Action Plan: To address the deficiencies identified in Finding 2025-001, the University has undertaken and continues to implement a comprehensive corrective action strategy focused on strengthening financial aid systems, standardizing processes, enhancing staff capacity, and institutional...

Corrective Action Plan: To address the deficiencies identified in Finding 2025-001, the University has undertaken and continues to implement a comprehensive corrective action strategy focused on strengthening financial aid systems, standardizing processes, enhancing staff capacity, and institutionalizing quality assurance and oversight mechanisms. Primary Control Enhancements. The University transitioned from PowerFAIDS to Ellucian Colleague as the system of record for financial aid awarding, enabling automated enforcement of packaging, eligibility, and fund-specific awarding rules. System configuration enhancements now support accurate cost of attendance calculations, enforcement of loan limits, and eligibility sequencing based on updated ISIR data, reducing reliance on manual intervention. Supporting Controls and Training. To support the implementation and stabilization of these controls, the University partnered with Financial Aid Services (FAS) in February 2025 to conduct a comprehensive review of financial aid systems, processes, and internal controls. Through this partnership, FAS has provided experienced Colleague specialists to support annual system setup, troubleshooting, validation of awarding rules, and targeted staff training. In addition, Financial Aid staff participate in ongoing professional development through the National Association of Student Financial Aid Administrators (NASFAA) and Federal Student Aid (FSA) to ensure continued proficiency and regulatory awareness. Monitoring and Quality Assurance. A formal quality assurance framework has been institutionalized, requiring eligibility and award accuracy reviews at least twice per semester. Reviews validate FSEOG prioritization by Student Aid Index (SAI), resolution of ISIR comment codes prior to disbursement, compliance with annual and lifetime loan limits, and alignment between cost-of-attendance values maintained in Ellucian Colleague and those reported to COD. Since the implementation of enhanced system controls and QA procedures, the University has conducted multiple eligibility and award accuracy reviews across Title IV programs, including Direct Loans, Pell Grants, and cost-ofattendance reconciliation. These reviews have demonstrated improved accuracy and control effectiveness, while also identifying isolated issues that were addressed through system updates or corrective adjustments. Sustained Oversight. Results of quality assurance reviews are documented, corrected, and analyzed to inform system configuration, staff training, and supervisory oversight. These controls ensure that improvements supported through the FAS partnership are institutionalized within university operations and sustained beyond the initial remediation period. Anticipated Completion Date: June 2026

View Audit 390365

Finding 1176542 (2025-004)

Material Weakness 2025

State of West Virginia

WV

Cash Management Reporting Student Financial Aid § 200.303

2025-004 REPORTING – CASH MANAGEMENT IMPROVEMENT ACT WEST VIRGINIA STATE TREASURER’S OFFICE (WVSTO) Assistance Listing Numbers: 10.551/10.561/10.555/17.225/20.205/84.010/84.027/84.425/93.558/93.568/ 93.575/93.658/93.659/93.767/93.778/97.036 For the Annual Report filing deadline, December 31, 2025, W...

2025-004 REPORTING – CASH MANAGEMENT IMPROVEMENT ACT WEST VIRGINIA STATE TREASURER’S OFFICE (WVSTO) Assistance Listing Numbers: 10.551/10.561/10.555/17.225/20.205/84.010/84.027/84.425/93.558/93.568/ 93.575/93.658/93.659/93.767/93.778/97.036 For the Annual Report filing deadline, December 31, 2025, WVSTO staff experienced multiple extenuating circumstances including training of newer staff members, medical treatments, illness, and the sudden unexpected passing of a close family member. Realizing that these circumstances would interfere with the timely submission of the Annual Report, an extension was requested on December 30, 2025, with the Bureau of the Fiscal Service and was granted through Friday, January 9, 2026. Regrettably, the extenuating circumstances were not fully resolved by that date, and the report was ultimately submitted on January 14, 2026. The WVSTO remained focused on completing the Report but overlooked the need to request an additional extension. WVSTO staff subsequently met with Angela Smith, Director of the Bureau of the Fiscal Service and staff members Mary Bailey and Christopher Bush from the Revenue Collections Management Team. Director Smith confirmed there will be no penalties assessed due to the late filing. Additionally, WVSTO Banking Services staff will review the internal timeline of CMIA activities and procedures to ensure that future reporting is complete and submitted in a timely manner.

View Audit 390319

Finding 1176515 (2025-011)

Material Weakness 2025

State of West Virginia

WV

Special Tests & Provisions Student Financial Aid Significant Deficiency § 200.303

2025-011 SPECIAL TESTS AND PROVISIONS: GRAMM-LEACH-BLILEY ACT SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE, OTHER MATTERS WEST VIRGINIA STATE UNIVERSITY (WVSU) Assistance Listing Numbers: 84.003/84.007/84.038/84.063/84.268/84.379 WVSU has begun the process of developing a written cyber...

2025-011 SPECIAL TESTS AND PROVISIONS: GRAMM-LEACH-BLILEY ACT SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE, OTHER MATTERS WEST VIRGINIA STATE UNIVERSITY (WVSU) Assistance Listing Numbers: 84.003/84.007/84.038/84.063/84.268/84.379 WVSU has begun the process of developing a written cybersecurity policy. However, due to the recently fluctuating landscape of cybersecurity, security needs involved, and the number of staff available for the task, WVSU has not yet completed, nor approved any policy beyond the preliminary stages. WVSU is committed to having a written cyber security policy by the end of 2025-2026 which will have been approved by WVSU administration. Further delaying the process was a change in CFO during FY 2026.

View Audit 390319

Finding 1176514 (2025-012)

Material Weakness 2025

State of West Virginia

WV

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

2025-012 SPECIAL TESTS AND PROVISIONS: NSLDS REPORTING WEST VIRGINIA UNIVERSITY (WVU), WEST VIRGINIA SCHOOL OF OSTEOPATHIC MEDICINE (WVSOM), SOUTHERN WEST VIRGINIA COMMUNITY AND TECHNICAL COLLEGE (SWVCTC) Assistance Listing Numbers: 84.063/84.268 West Virginia University (WVU) response: The Office o...

2025-012 SPECIAL TESTS AND PROVISIONS: NSLDS REPORTING WEST VIRGINIA UNIVERSITY (WVU), WEST VIRGINIA SCHOOL OF OSTEOPATHIC MEDICINE (WVSOM), SOUTHERN WEST VIRGINIA COMMUNITY AND TECHNICAL COLLEGE (SWVCTC) Assistance Listing Numbers: 84.063/84.268 West Virginia University (WVU) response: The Office of the University Registrar (OUR) will create an “enrollment effective date validation” step in our comparison process. OUR will take the NSC submission file generated by WVU Information Technology Services (ITS) and compare the program effective date and campus enrollment effective date for each student to ensure the dates match. Any dates that do not match will be documented or corrected. West Virginia School of Osteopathic Medicine (WVSOM) response: As of December 2025, WVSOM updated the program enrollment date within the graduation spreadsheet processed out of the Banner system. Going forward, WVSOM registrar will create a calendar reminder to confirm program enrollment on the spreadsheet. The reminder function will be used to ensure this step is not missed in the future. WVSOM registrar will check the report diligently for accuracy. Southern West Virginia Community and Technical College (SWVCTC) response: SWVCTC is consulting with the Clearinghouse to better understand and identify any data elements of concern. SWVCTC is working to resubmit enrollment files and will review each file to ensure the data and processes are correct. An internal review by the CIO and Registrar will be done on each submission for a period of at least six months or until all parties are satisfied with the submissions.

View Audit 390319

Finding 1176512 (2025-010)

Material Weakness 2025

State of West Virginia

WV

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

2025-010 CASH MANAGEMENT GLENVILLE STATE UNIVERSITY (GSU), SOUTHERN WEST VIRGINIA COMMUNTY AND TECHNICAL COLLEGE (SWVCTC) Assistance Listing Numbers: 84.063/84.268 Glenville State University (GSU) Response: As of December 2024, the Glenville State University (GSU) Financial Aid Office, in conjunctio...

2025-010 CASH MANAGEMENT GLENVILLE STATE UNIVERSITY (GSU), SOUTHERN WEST VIRGINIA COMMUNTY AND TECHNICAL COLLEGE (SWVCTC) Assistance Listing Numbers: 84.063/84.268 Glenville State University (GSU) Response: As of December 2024, the Glenville State University (GSU) Financial Aid Office, in conjunction with the GSU Business and Finance Office, has implemented policies and procedures to perform, at a minimum, monthly Pell Grant and Direct Loan reconciliations, with the appropriate signoffs. The GSU Financial Aid Office reviews and reconciles all Pell Grant and Direct Loan disbursement records at least monthly by comparing Banner records to Common Origination and Disbursement (COD) records. If any do not match, the GSU Financial Aid Office notes this within their documentation and resolves these discrepancies in a timely manner. They are reconciled by the GSU Financial Aid Office, signed off by the reconciling staff member, as well as the Financial Aid Director. Further, the GSU Business and Finance Office Accountant and GSU Financial Controller review and sign-off the reconciled data. The final copy is kept within the GSU Financial Aid Office. 78 Southern West Virginia Community and Technical College (SWVCTC) Response: A Monthly Reconciliation Cover Sheet has been developed. The Financial Aid Counselor will complete the monthly and annual reconciliation for each fund (e.g., Pell Grant, Student Loans). The cover sheet will document the month reconciled, the fund being reconciled, the amount disbursed in Banner, the amount disbursed through COD, any discrepancies with explanations, and the preparer’s signature. The applicable SAS Reconciliation for each fund will be attached to the cover sheet. Upon completion, the reconciliation and cover sheet will be reviewed and approved by the Director of Student Financial Assistance.

View Audit 390319

Finding 1176485 (2025-003)

Material Weakness 2025

Claflin University

SC

Student Financial Aid Eligibility

The University acknowledges the Pell Grant under award identified during the audit. University officials have developed the following corrective actions to ensure correct calculation of Pell Grant awards in accordance with 34 CFR §690.75. To correct the underlying problem, Financial Aid staff will w...

The University acknowledges the Pell Grant under award identified during the audit. University officials have developed the following corrective actions to ensure correct calculation of Pell Grant awards in accordance with 34 CFR §690.75. To correct the underlying problem, Financial Aid staff will work directly with Power FAIDS support to identify the specific cause(s) of the miscalculation of Pell Grant awarding. The University will also enhance staff competency through targeted training on the Pell Grant calculation methodology. All training activities will be documented and maintained in office records as part of the University’s compliance documentation. Additionally, the University will develop and revise internal policies and procedures related to Pell Grants to ensure consistency, accuracy, and adherence to federal regulations. These updated procedures will guide staff in the correct application of Pell rules and system processes. Further, to ensure ongoing compliance, the University will implement monitoring and quality‑assurance measures. These measures will include the conduct of monthly internal audits by an internal reviewer within Financial Aid to ensure Pell award accuracy. Monitoring results will be reviewed by the Director of Financial Aid and reported to the Vice President for Enrollment Management for oversight and accountability. Finally, these officials will ensure that the financial aid software used by the University is properly configured and maintained to address and prevent future awarding issues.

View Audit 390298

Finding 1176476 (2025-001)

Material Weakness 2025

Salem State University

MA

Student Financial Aid Reporting § 200.303

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster AL #: 84.063 and 84.268 Award year: 2025 Corrective Action Plan: This issue was the result of human error, as established procedures were not followed in which a student withdrawal wa...

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster AL #: 84.063 and 84.268 Award year: 2025 Corrective Action Plan: This issue was the result of human error, as established procedures were not followed in which a student withdrawal was not forwarded to the Registrar’s Office, preventing timely reporting to NSLDS. The student’s official withdrawal request was not transmitted by the office responsible for approving student leaves and withdrawals to the Registrar’s Office for processing, resulting in the absence of the required enrollment update in the student information system. In response, the Registrar’s Office has implemented a revised procedure for the handling of late leave requests and will coordinate directly with the Financial Aid Office to ensure accurate updates to the NSLDS. Staff in the Advising Office have been retrained on proper transmission protocols, and both the Registrar’s Office and Advising Office have instituted additional quality control and tracking measures to ensure that all leaves and withdrawals are processed and reported in a timely and compliant manner. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2025. Contact Person Megan Miller, University Registrar

View Audit 390287

Finding 1176462 (2025-002)

Material Weakness 2025

The Corporation of Haverford College

PA

Student Financial Aid Reporting Significant Deficiency

Common Origination and Disbursement (COD) Reporting Recommendation: We recommend the College evaluate its policies and procedures around reporting to the COD to ensure that information is reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit fin...

Common Origination and Disbursement (COD) Reporting Recommendation: We recommend the College evaluate its policies and procedures around reporting to the COD to ensure that information is reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: A PELL reconciliation report will be pulled monthly to check that the disbursement dates/amounts on COD match the disbursement dates/amounts on PowerFAIDS and Bionic. Name of the contact person responsible for corrective action: Shannon Braccili, Associate Director of Financial Aid Planned completion date for corrective action plan: Effective starting August 2025 with the first Fall 2025 PELL disbursement and continuing through the end of the academic year. This procedure will continue to be followed in subsequent academic years.

View Audit 390280

Finding 1176461 (2025-001)

Material Weakness 2025

The Corporation of Haverford College

PA

Student Financial Aid Reporting Significant Deficiency

U.S. Department of Education National Student Loan Data Systems (NSLDS) Enrollment Reporting - Federal Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that a...

U.S. Department of Education National Student Loan Data Systems (NSLDS) Enrollment Reporting - Federal Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An investigation that uncovered a National Student Clearinghouse enrollment transmission proofing error related to program-level effective date for graduated students. Name of the contact person responsible for corrective action: James Keane, Registrar Planned Corrective Action Plan: The Registrar's Office will ensure that the program level effective date for graduates is accurate prior to submission. The Registrar will also partner with IITS to ensure that the program-level effective date for graduates is generated in the submission file as expected. Planned completion date for corrective action plan: May 2026, prior to the June 2026 submission date.

View Audit 390280

Finding 1176366 (2025-001)

Material Weakness 2025

Delaware Valley University

PA

Student Financial Aid Reporting Significant Deficiency

Recommendation: The University should review its policies and procedures on determining student's withdrawals and timely communication among departments to ensure timely returns of Title IV funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action...

Recommendation: The University should review its policies and procedures on determining student's withdrawals and timely communication among departments to ensure timely returns of Title IV funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University automated the process of communicating withdrawals between departments a few years ago. Unfortunately, an individual responsible for communicating withdrawals failed to use the system in that instance. When the delay in process was discovered, the offices of Student Support, Registrar, Financial Aid, and Bursar met to review communication and documentation processes. Meetings occurred in Summer 2025 to implement a cohesive process. The corrective action is that dismissals related to student conduct follow the same agreed upon process that hiatus and withdrawal follow. The responsible individual no longer works at the University, and their replacement will be fully trained and using the system in place. Name(s) of the contact person(s) responsible for corrective action: Andrew Moyer Planned completion date for corrective action plan: March 31, 2026

View Audit 390188

Finding 1176358 (2025-001)

Material Weakness 2025

Jamestown Community College

NY

Student Financial Aid Subrecipient Monitoring Equipment & Real Property Management

The College agrees with the finding. While many GLBA-required safeguards are operationally in place, documentation and a formal enterprise risk assessment have not been fully completed. The College will engage a qualified third party to perform a comprehensive GLBA-aligned risk assessment using a re...

The College agrees with the finding. While many GLBA-required safeguards are operationally in place, documentation and a formal enterprise risk assessment have not been fully completed. The College will engage a qualified third party to perform a comprehensive GLBA-aligned risk assessment using a recognized framework such as NIST. Based on the results, the College will document identified risks, existing safeguards, and remediation plans. Additionally, the College will formalize and update its Written Information Security Program, including policies addressing vendor management, user access controls, data transmission and destruction, change management, and data inventory. Policies will be reviewed and approved through the College’s governance process. Responsible Party: Kyle Brown, Executive Director of Technology, Jamestown Community College, kylebrown@sunyjcc.edu, 716.338.1118 Anticipated Completion Date: August 31, 2026

View Audit 390178

Finding 1176209 (2025-004)

Material Weakness 2025

El Camino Community College District

CA

Student Financial Aid Reporting

Recommendation: We recommend the District review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: During the 2024-2025 audit, two enrollment records were reported late to NSLDS ...

Recommendation: We recommend the District review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: During the 2024-2025 audit, two enrollment records were reported late to NSLDS in October 2024. The late reporting occurred prior to the implementation of the corrective action plan developed during the 2023–2024 audit period. The previously identified cause was timing gaps between Clearinghouse file submission and NSLDS processing. Corrective Action Taken: The corrective action plan from the 2023–2024 audit period was fully implemented as of Spring 2025 and has addressed the root cause of the late reporting. Actions implemented include: • Reviewed and documented enrollment reporting timelines from Clearinghouse submission through NSLDS posting. • Established consistent file submission schedules aligned with NSLDS reporting deadlines. • Formalized communication and escalation procedures with the Clearinghouse and NSLDS, including designated points of contact. • Updated internal policies and procedures to reflect revised reporting timelines. • Provided training to staff responsible for enrollment reporting, emphasizing timeliness and compliance requirements. • Implemented monitoring controls to track file submission, acceptance, and processing by NSLDS. The 2023-2024 audit corrective action plan was successfully implemented in Spring 2025. Since implementation, no additional late enrollment reporting instances have occurred. Moving forward, it is expected that enrollment reporting to NSLDS will be timely and compliant with federal requirements, supported by documented procedures and ongoing monitoring controls. Name of the contact person responsible for corrective action: Dr. Kristina Martinez, Acting Dean of Enrollment Services Planned completion date for corrective action plan: June 30, 2026

View Audit 390070

Finding 1176205 (2025-003)

Material Weakness 2025

El Camino Community College District

CA

Student Financial Aid Matching / Level of Effort / Earmarking

Recommendation: We recommend the District continue to enhance and consistently apply R2T4 procedures by providing ongoing training to staff responsible for R2T4 calculations and by continuing with additional reviews and quality control measures to ensure accuracy and compliance. Action taken in resp...

Recommendation: We recommend the District continue to enhance and consistently apply R2T4 procedures by providing ongoing training to staff responsible for R2T4 calculations and by continuing with additional reviews and quality control measures to ensure accuracy and compliance. Action taken in response to finding: The District acknowledges the importance of compliance with Return to Title IV (R2T4) requirements. The repeat finding cited in the subsequent audit relates to files processed prior to implementation of the corrective action plan. Since implementation, the District has not identified any new R2T4 errors or compliance issues. Action taken in response to finding: 1. Prior-Year File Remediation • Recalculated R2T4 amounts for affected students. • Returned required funds to the U.S. Department of Education. 2. Oversight and Review Controls • Engaged a NASFAA-certified consultant to review all R2T4 calculations during the 2024–2025 aid year. • Implemented secondary internal review of all R2T4 calculations. 3. Training and Staffing Enhancements • Completed department-wide and R2T4-specific training. • R2T4 staff completed NASFAA R2T4 course series. • An additional Accounting Officer position was added to support R2T4 processing and reconciliation with appropriate system access. 4. Process Improvements • Transitioned to the Department of Education’s R2T4 worksheet in COD. • Established formal coordination with Academic Affairs and the Registrar. • Updated R2T4 training and job aids. 5. Ongoing Monitoring • Management performs periodic internal reviews of R2T4 files. • The District continues to evaluate system and reporting enhancements. Conclusion Although the audit included R2T4 files processed prior to corrective action implementation, the District’s actions have been effective. No new R2T4 issues have been identified since implementation, and controls are in place to ensure ongoing compliance. Name of the contact person responsible for corrective action: David Brown, Acting Director of Financial Aid & Basic Needs Planned completion date for corrective action plan: June 30, 2026

View Audit 390070

Corrective Action Plans

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