Corrective Action Plans

Finding 1205225 (2025-001)

Material Weakness 2025

Rutgers, the State University of New Jersey

NJ

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

2025-001 Eligibility, Reporting (Financial) and Special Tests (Disbursements to or on Behalf of Students) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education and U.S. Department of Health and Human Services (DHHS), DHHS Health Resources and Services Administration Pro...

2025-001 Eligibility, Reporting (Financial) and Special Tests (Disbursements to or on Behalf of Students) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education and U.S. Department of Health and Human Services (DHHS), DHHS Health Resources and Services Administration Program Titles and Assistance Listing Numbers (ALN): Federal Supplemental Educational Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Perkins Loans (ALN 84.038), Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268), Nurse Faculty Loan Program (ALN 93.264), Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students (ALN 93.342), Nursing Student Loans (ALN 93.364), Scholarships for Health Professions Students from Disadvantaged Backgrounds (ALN 93.925) Federal Grant Numbers: E P007A252602 (7/1/2024 – 6/30/2025), E P033A252602 (7/1/2024 – 6/30/2025), E P038A132602 (7/1/2024 – 6/30/2025), E P063P250272 (7/1/2024 – 6/30/2025), P268K260272 (7/1/2024 – 6/30/2025), E-01HP28821-02-02, E-01HP31830-01-00,(7/1/2024 – 6/30/2025), E4CHP42498-01-00 (7/1/2024 – 6/30/2025), E26HP25750, E36HP25751, E11HP27284, E36HP26092, E36HP25751, E26HP25748 (7/1/2024 – 6/30/2025) Contact Person: Robert Fahy, AVP of University Enrollment Services, 848-932-2603 Corrective Action: Since the audit period, the University has strengthened governance and oversight over OSFP by formalizing access controls and reinforcing monitoring practices. Management has established and documented OSFP system roles and responsibilities. A review of user access was performed to ensure alignment with job responsibilities, and users holding multiple or incompatible roles were corrected. In addition, the University implemented an audit log to track user provisioning and deprovisioning activity, providing documented evidence of access changes and removals. The University has also enhanced its change management process to ensure that all updates to OSFP follow the documented change management procedures. These measures collectively strengthen logical access and change management controls and support effective internal control over system operations. Management will continue to monitor the effectiveness of these controls. Anticipated Completion Date: Completed

View Audit 396899

Finding 1205215 (2025-002)

Material Weakness 2025

McKendree University

IL

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Student Financial Assistance Cluster Federal Direct Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate controls around monitoring return of Title IV funds to determine changes, either on the electronic processes or review processes that should be made to prope...

Student Financial Assistance Cluster Federal Direct Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate controls around monitoring return of Title IV funds to determine changes, either on the electronic processes or review processes that should be made to properly capture return of Title IV funds on a timely basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Planned corrective action: Currently, the return of Title IV calculations are done manually and a second person within Financial Aid reviews the calculation. The University is working on a training engagement for the Financial Aid office which will explore the ability to perform the return of Title IV calculations within the ERP system. A second person would continue to review the calculation. Name(s) of the contact person(s) responsible for corrective action: Patrick Michael, Director of Financial Aid If the United States Department of Education has questions regarding this plan, please call Shari Keffer, Vice President for Administration & Finance at 618-537-6838.

View Audit 396879

Finding 1205214 (2025-001)

Material Weakness 2025

McKendree University

IL

Student Financial Aid Special Tests & Provisions

Student Financial Assistance Cluster Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate controls around monitoring enrollment reporting to determine changes, either on the electronic pro...

Student Financial Assistance Cluster Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate controls around monitoring enrollment reporting to determine changes, either on the electronic processes or review processes, that should be made to properly capture enrollment status changes on a timely basis and to properly monitor its third-party service provider for timely reporting as necessary. Planned corrective action: Processes will be reviewed and updated to ensure submissions are being reported timely and accurately Name(s) of the contact person(s) responsible for corrective action: Patrick Michael, Director of Financial Aid If the United States Department of Education has questions regarding this plan, please call Shari Keffer, Vice President for Administration & Finance at 618-537-6838.

View Audit 396879

Finding 1205208 (2025-006)

Material Weakness 2025

Salem Community College

NJ

Special Tests & Provisions Student Financial Aid Reporting

Views of Responsible Officials: SCC’s implementation of Student First on August 10, 2026, will help rectify the enrollment reporting issues.

View Audit 396871

Finding 1205190 (2025-001)

Material Weakness 2025

The Cooper Union for the Advancement of Science and Art

NY

Student Financial Aid

The Enrollment Division at The Cooper Union has seen recent turnover in leadership and personnel coinciding with the 2024-2025 data submission cycle. A new Vice President for Enrollment, Troy Cogburn, joined the community in October 2024 and the College experienced continued transition and turnover....

The Enrollment Division at The Cooper Union has seen recent turnover in leadership and personnel coinciding with the 2024-2025 data submission cycle. A new Vice President for Enrollment, Troy Cogburn, joined the community in October 2024 and the College experienced continued transition and turnover. In May 2025, an Assistant Registrar was hired, and Troy stepped in as Interim Registrar, while also overseeing a search to fill the position permanently, which did not come to fruition until a new Senior Registrar was hired/started working for The Cooper Union during the first week of January 2026. Moving forward, the new Senior Registrar, Bryan Cracchiolo, has resumed responsibilities for timely enrollment and graduation reporting through the National Clearinghouse. Additionally, Bryan is working in closer collaboration with the Offices of Institutional Effectiveness and Research, to ensure accurate processing of all institutional data. Furthermore, the Vice President and Senior Registrar, as an interim step, are teaming with campus executive leadership to revisit a long-held, multi-step conferral confirmation practice which has contributed to certain delays in the processing of student enrollment records. Their goal is to implement an expedited review process by the Spring of 2026 that will lead to the timely submission of student enrollment changes to the NSLDS.

View Audit 396847

Finding 1205160 (2025-004)

Material Weakness 2025

Beacon College, Inc.

FL

Reporting Student Financial Aid Significant Deficiency

Recommendation: We recommend the College evaluate its policies and procedures around reporting student status changes to NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: Ther...

Recommendation: We recommend the College evaluate its policies and procedures around reporting student status changes to 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 planned/taken in response to finding: Internal Control Enhancement: The Registrar will update the department’s internal control procedures to include a scheduled monitoring process to ensure that all enrollment status changes are reviewed and reported to NSLDS within 60 days. The procedure will also include a verification step to document when a student qualifies under the limited exception policy, ensuring appropriate justification is maintained for any enrollment updates reported outside the 60-day timeframe. Periodic reconciliation between the Student Information System and NSLDS reporting records will be conducted to confirm that all enrollment changes are transmitted within the required reporting period. Name(s) of the contact person(s) responsible for corrective action: Carrie Santaw, Bursar Planned completion date for corrective action plan: April 1, 2026

View Audit 396825

Finding 1205159 (2025-003)

Material Weakness 2025

Beacon College, Inc.

FL

Student Financial Aid Eligibility Significant Deficiency

Recommendation: We recommend the College evaluate its procedures around packaging and awarding students to ensure loan eligibility is reassessed prior to disbursement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to...

Recommendation: We recommend the College evaluate its procedures around packaging and awarding students to ensure loan eligibility is reassessed prior to disbursement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: 􀁸 The College determined that this issue resulted from the absence of a consistent process to identify and reassess students whose transfer credits were added or revised after initial financial aid packaging, potentially affecting grade level classification and Direct Loan eligibility. 􀁸 To correct this, the College will revise its packaging procedures to require a mandatory review of Direct Loan eligibility whenever transfer credits are added or updated. The Financial Aid Office will work in coordination with the IT Department and the Registrar’s Office to develop automated reports or system alerts that flag students with transfer credit changes occurring after packaging. These reports will be reviewed regularly, and any impacted student records will be reassessed and updated as necessary prior to disbursement. 􀁸 In addition, the College will strengthen oversight by implementing monitoring controls such as requirements. These measures are intended to prevent future instances of under-awarding and to enhance internal controls within the financial aid packaging and awarding process. Name(s) of the contact person(s) responsible for corrective action: Stephanie Liebowitz, Director of Financial Aid Planned completion date for corrective action plan: April 15, 2026 – Procedures will be in place for the awards cycle of the incoming 2026-2027 class.

View Audit 396825

Finding 1205158 (2025-002)

Material Weakness 2025

Beacon College, Inc.

FL

Student Financial Aid Material Weakness Internal Control / Segregation of Duties

Recommendation: We recommend the College evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe. Explanation of disagreement with audit finding: There is no disagreeme...

Recommendation: We recommend the College evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The institution will conduct a comprehensive policy review related to student accounts and financial aid disbursements. The Student Accounts team will receive retraining, including additional Financial Aid–specific training focused on federal guidelines and compliance requirements. Cross training will be implemented within the Student Accounts team to prevent delays and ensure continuity of operations when staff are on leave. Ongoing communication protocols will also be reinforced between Student Accounts and the outsourced financial aid staffing team (Financial Aid Services (FAS)) regarding disbursement timing to promote coordination and timeliness. Name(s) of the contact person(s) responsible for corrective action: Scott Crawford, Director of Accounting and Melissa Ogelvie, Bursar Planned complet ion date for corrective action plan: July 1, 2027 – While we anticipate improvement in these processes throughout the training process, completion of these corrective actions will be complete by this date. This timeline accounts for the identification, scheduling, and completion of appropriate training opportunities, including potential external training or professional development programs that may require advance enrollment and availability.

View Audit 396825

Finding 1205156 (2025-001)

Material Weakness 2025

Edp University of Puerto Rico, Inc.

PR

Student Financial Aid

The institution has reinforced its R2T4 internal training program and continues to monitor withdrawals to detect and proceed promptly with any deviation to the application of the regulations for this purpose.To prevent recurrence and ensure full compliance with Federal Student Aid regulations, our i...

The institution has reinforced its R2T4 internal training program and continues to monitor withdrawals to detect and proceed promptly with any deviation to the application of the regulations for this purpose.To prevent recurrence and ensure full compliance with Federal Student Aid regulations, our institution has initiated the following actions:Report Modification: We have formally requested the modification of two specific monitoring reports (class status audit report/selected letter grade report). These enhancements will ensure that all students are correctly flagged for R2T4 (Return to Title IV) calculations. We will continue exploring reports and configurations in our system (SIS) that will serve as tools to perform these verifications more efficiently.Staff Training: The Bursars teams are undergoing training sessions focused on identifying "hidden" withdrawals and mastering the updated reporting tools.Increased Monitoring Frequency: We have transitioned to every two weeks monitoring of student enrollment status with weekly detailed evaluation of courses identified as withdrawals. This ensures that any "unofficial withdrawals" or "drop-outs" are captured within the required regulatory window.We take our fiduciary responsibility regarding Title IV funds very seriously. We are confident that the integration of more frequent reviews and the refinement of our reporting software will eliminate the gap that led to this finding.

View Audit 396819

Finding 1205140 (2025-022)

Material Weakness 2025

State of Arkansas

AR

Student Financial Aid Subrecipient Monitoring Eligibility

Finding Number: 2025-022 ALN Number(s) and Program Title(s): 93.658 – Title IV-E Foster Care Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. DCFS will conduct a review to determine if additional controls are needed to ensure that foster homes complete all...

Finding Number: 2025-022 ALN Number(s) and Program Title(s): 93.658 – Title IV-E Foster Care Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. DCFS will conduct a review to determine if additional controls are needed to ensure that foster homes complete all required checks. All improper Title IV-E payments will be returned on the next CB-496 quarterly report. Anticipated Completion Date: 4/30/2026 Contact Person: Name: Tiffany Wright Title: Director, Division of Children and Family Services Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-396-6477 Email Address: Tiffany.Wright@dhs.arkansas.gov

View Audit 396807

Finding 1205138 (2025-020)

Material Weakness 2025

State of Arkansas

AR

Student Financial Aid Subrecipient Monitoring Allowable Costs / Cost Principles

Finding Number: 2025-020 ALN Number(s) and Program Title(s): 93.658 – Title IV-E Foster Care Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. The reconciliation process will be revised to specify steps to identify clients that are eligible to receive Title...

Finding Number: 2025-020 ALN Number(s) and Program Title(s): 93.658 – Title IV-E Foster Care Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. The reconciliation process will be revised to specify steps to identify clients that are eligible to receive Title IV-E funding and the process to update their IV-E status. The agency could not make the necessary corrections in AASIS when notified of the deficiency due to the expenses being posted in the prior fiscal year. All necessary adjustments will be made on the quarterly report for the period ending on 3/31/26. Anticipated Completion Date: 4/30/26 Contact Person: Name: Tiffany Wright Title: Director, Division of Children and Family Services Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-396-6477 Email Address: Tiffany.Wright@dhs.arkansas.gov

View Audit 396807

Finding 1205115 (2025-002)

Material Weakness 2025

Caribbean University, Inc.

PR

Student Financial Aid

Critical Deadline Controls Implementation of internal tracking alerts to monitor the 45-day regulatory deadline.Tracking calendar for each withdrawn student.Interdepartmental Coordination Review and update of protocols between Academic Departments Registrar, Financial Aid, and Finance.Immediate noti...

Critical Deadline Controls Implementation of internal tracking alerts to monitor the 45-day regulatory deadline.Tracking calendar for each withdrawn student.Interdepartmental Coordination Review and update of protocols between Academic Departments Registrar, Financial Aid, and Finance.Immediate notification of student withdrawals.Process Standardization Development of detailed procedures for calculation and return of funds.Use of standardized checklists for each R2T4 case.Oversight and Review Weekly review and validation withdrawals, drops of pending R2T4 cases. Monthly reconciliation of withdrawal reports submitted by the Registrar Office.Technical Training Specialized training in R2T4 calculations and federal compliance

View Audit 396799

Finding 1205113 (2025-001)

Material Weakness 2025

Caribbean University, Inc.

PR

Student Financial Aid Matching / Level of Effort / Earmarking

Reporting Controls and Monitoring Implementation of a fixed NSLDS reporting calendar.Monthly validation of enrollment status changes (withdrawals, drops, enrollment level changes).Accountability and OversightAssignment of dedicated personnel responsible for Enrollment Reporting.Supervisory review an...

Reporting Controls and Monitoring Implementation of a fixed NSLDS reporting calendar.Monthly validation of enrollment status changes (withdrawals, drops, enrollment level changes).Accountability and OversightAssignment of dedicated personnel responsible for Enrollment Reporting.Supervisory review and approval prior to submission of each report.Targeted Training Focused training on NSLDS compliance and federal regulations.Cross-training to reduce dependency on a single staff member Procedural Enhancements Review and update of established process between Academic Departments and the Registrar Office to unsure proper identification of students who have fulfilled graduation requirements.Implementation of reporting checklists to ensure compliance at each cycle.Systems Integration Review and validation of integration between internal systems and NSLDS/Clearinghouse to ensure data accuracy.

View Audit 396799

Finding 1205111 (2025-004)

Material Weakness 2025

Saint Vincent College Corporation

PA

Student Financial Aid Reporting

Finding 2025-004 - Enrollment Reporting: Untimely Status Update Condition: One student who graduated in December 2024 was not reported within the required 60-day timeframe. Corrective Action Plan: The College will strengthen enrollment reporting controls within Colleague by: • Performing a monthly r...

Finding 2025-004 - Enrollment Reporting: Untimely Status Update Condition: One student who graduated in December 2024 was not reported within the required 60-day timeframe. Corrective Action Plan: The College will strengthen enrollment reporting controls within Colleague by: • Performing a monthly reconciliation between Registrar records and enrollment reporting files submitted to NSLDS. • Utilizing Colleague reporting tools to identify recent graduates and status changes requiring updates. • Establishing a compliance calendar with system reminders for required reporting deadlines. • Training staff on reporting requirements aligned with the National Student Loan Data System. Responsible Party: Mandy Schnorr, Director of Financial Aid, Cara Moyer, Registrar Anticipated Completion Date: June 30, 2026

View Audit 396784

Finding 1205095 (2025-002)

Material Weakness 2025

Eastland Fairfield Career & Technical Schools

OH

Student Financial Aid

The District acknowledges the finding related to the reporting of origination records to the Common Origination and Disbursement (COD) system in accordance with 34 CFR § 668.408(a)(2). The determination is that the discrepancy was the result of a manual data entry error during the preparation and su...

The District acknowledges the finding related to the reporting of origination records to the Common Origination and Disbursement (COD) system in accordance with 34 CFR § 668.408(a)(2). The determination is that the discrepancy was the result of a manual data entry error during the preparation and submission of the origination record. The issue was isolated to a single record within the sample reviewed and does not reflect a systemic reporting issue. Upon identification, the District verified the correct cost of attendance information in the student’s file and updated the record in the COD system to ensure it accurately reflects the supporting documentation. The District recognizes the importance of Title IV funding and takes the accuracy of Title IV reporting seriously and has implemented additional internal control procedures to strengthen oversight of origination record submissions, including a secondary review of key data elements, such as cost of attendance, prior to submission of origination records to the COD system and ensuring all required data fields align with the student’s supporting documentation. These corrective actions are intended to ensure that the information reported in the COD system is accurate and consistent with the documentation maintained in student files, thereby maintaining compliance with federal reporting requirements and safeguarding the integrity of Title IV program administration.

View Audit 396748

Finding 1205093 (2025-002)

Material Weakness 2025

Wisconsin Lutheran College, Inc.

WI

Student Financial Aid

2025-002 - The College must provide an original signature on the printed form that must be mailed or hand delivered by the first of October deadline date. (34 CFR 668.24). Condition: The College submitted the FISAP to the Department fourteen days after the requirement due to President being out of t...

2025-002 - The College must provide an original signature on the printed form that must be mailed or hand delivered by the first of October deadline date. (34 CFR 668.24). Condition: The College submitted the FISAP to the Department fourteen days after the requirement due to President being out of the country. We consider this to be an instance of noncompliance in relation to Reporting and is not a repeat finding. Statistical sampling was not used. Responsible Person: Robert Emerson - Director of Financial Aid Corrective Action Plan: The FISAP is available for completion during the months of August and September, with a deadline of October 1st. To avoid potential future schedule issues, the Financial Aid office will target a completion date no later than September 10th. This will ensure our ability to obtain an original signature and mail the application in a timely manner. Implementation Date: 10-22-2025

View Audit 396743

Finding 1205089 (2025-001)

Material Weakness 2025

Wisconsin Lutheran College, Inc.

WI

Student Financial Aid Special Tests & Provisions

2025-001 - Sikich tested twenty drop students and found one incorrect refund calculation and one untimely paid refund (10%). We consider this finding to be an instance of non-compliance in relation to Special Tests and Provisions and a repeat of prior year finding 2024-001. Statistical sampling was ...

2025-001 - Sikich tested twenty drop students and found one incorrect refund calculation and one untimely paid refund (10%). We consider this finding to be an instance of non-compliance in relation to Special Tests and Provisions and a repeat of prior year finding 2024-001. Statistical sampling was not used. Responsible Person: Robert Emerson - Director of Financial Aid Corrective Action Plan: Withdrawals are processed by Dean of Academic Success and forwarded to Registrar and Financial Aid Office for review and action. The Financial Aid Office will begin to track and confirm the dates provided for withdrawals, last dates of attendance and disbursement to ensure that funds are returned accurately and in a timely manner. Implementation Date: 10-22-2025

View Audit 396743

Finding 1205085 (2025-001)

Material Weakness 2025

Mount St. Mary's University

MD

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

Identifying Number: 2025-001 Finding: For sixteen out of forty students tested who had enrollment changes at the University, the student’s status effective dates at the campus level and program level were not reported to the NSLDS timely. Corrective Actions Taken or Planned: We agree with the findin...

Identifying Number: 2025-001 Finding: For sixteen out of forty students tested who had enrollment changes at the University, the student’s status effective dates at the campus level and program level were not reported to the NSLDS timely. Corrective Actions Taken or Planned: We agree with the finding. The delays in reporting were identified beginning in December 2024 with the hire of a new registrar and since that time we have caught up with reporting requirements are now timely. We have also increased our cross-training efforts in the department, training multiple individuals on NSC reporting procedures, in order to ensure that if turnover were to occur again in the future there are other individuals who can perform the required functions. Person(s) Responsible for Corrective Actions: Katie Soter, Registrar Anticipated Completion Date: Completed

View Audit 396741

Finding 1205077 (2025-001)

Material Weakness 2025

Lakeland University and Affiliate

WI

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Student Financial Aid Cluster – Assistance Listing 84.007 – Federal Supplemental Educational Opportunity Grants; 84.063 –Federal Pell Grant Program; 84.268 – Federal Direct Loan Program Recommendation: We recommend the University evaluate its monitoring controls over outstanding Title IV refund chec...

Student Financial Aid Cluster – Assistance Listing 84.007 – Federal Supplemental Educational Opportunity Grants; 84.063 –Federal Pell Grant Program; 84.268 – Federal Direct Loan Program Recommendation: We recommend the University evaluate its monitoring controls over outstanding Title IV refund checks and credit balances to ensure that funds are returned to the Secretary no later than 240 days after the date the University issued the payment and credit balance payments are made within the 14-day requirement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will implement a regular review process of all outstanding Title IV payments and monitoring procedures of credit balance payments during the year. Name(s) of the contact person(s) responsible for corrective action: Lenora Stuckmann, Vice President for Finance and Chief Financial Officer Planned completion date for corrective action plan: 06/30/2026. If there are any questions regarding this plan, please call Lenora Stuckmann at 920-565-1027

View Audit 396714

Finding 1205064 (2025-009)

Material Weakness 2025

School District of Polk County, Florida

FL

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Gramm-Leach-Bliley Act Recommendation: We recommend that the District update its written information security program to ensure it includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: ...

Gramm-Leach-Bliley Act Recommendation: We recommend that the District update its written information security program to ensure it includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: The District will review and update its written information security program to ensure all required elements are included and fully aligned with applicable state and federal requirements. Updates will be completed and implemented in coordination with the appropriate departments to ensure compliance and ongoing monitoring. Responsible party: Director of Network Operations & Senior Director of Information Services Planned completion date for corrective action plan: April 30, 2026 Plan to monitor completion of corrective action plan: • The Director of Network Operations and Senior Director of Information Services will conduct periodic reviews to verify that updates to the information security program are completed, documented, and implemented as intended. • Progress will be reviewed with relevant departments to ensure ongoing compliance and to address any gaps identified during implementation.

View Audit 396707

Finding 1205063 (2025-008)

Material Weakness 2025

School District of Polk County, Florida

FL

Student Financial Aid Cash Management Material Weakness

240 Day Outstanding Payments Recommendation: We recommend the District implement a review process for outstanding student payments to ensure any that include Title IV funds are refunded to the U.S. Department of Education within 240 days. Explanation of disagreement with audit finding: There is no d...

240 Day Outstanding Payments Recommendation: We recommend the District implement a review process for outstanding student payments to ensure any that include Title IV funds are refunded to the U.S. Department of Education within 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: The Financial Aid Coordinator will create and maintain a SharePoint spreadsheet to effectively track and monitor outstanding student payments. The Workforce Finance Department will support the setup and ensure the spreadsheet aligns with established financial monitoring practices. Responsible party: Financial Aid Coordinator and Workforce Finance Department Planned completion date for corrective action plan: April 30, 2026 Plan to monitor completion of corrective action plan: The Financial Aid Coordinator and Workforce Finance Department will conduct monthly reviews to ensure the spreadsheet is updated, accurate, and used consistently for monitoring outstanding payments.

View Audit 396707

Finding 1205062 (2025-007)

Material Weakness 2025

School District of Polk County, Florida

FL

Special Tests & Provisions Student Financial Aid Eligibility

Special Tests and Provisions Recommendation: It is recommended that the District strengthen its internal controls over the R2T4 calculation process by implementing a secondary review or quality-assurance check of scheduled clock hours prior to finalizing R2T4 calculations. Staff should receive targe...

Special Tests and Provisions Recommendation: It is recommended that the District strengthen its internal controls over the R2T4 calculation process by implementing a secondary review or quality-assurance check of scheduled clock hours prior to finalizing R2T4 calculations. Staff should receive targeted training on the requirements of 34 CFR § 668.22, particularly regarding the use of scheduled hours in determining earned aid and post-withdrawal disbursement eligibility. Additionally, standardized calculation worksheets or system-generated hour reports should be utilized to reduce reliance on manual entry and minimize the risk of human error. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: Financial Aid Coordinators from both technical colleges will collaborate to review and audit each other's RT24 calculations to ensure accuracy, accountability, and compliance with regulatory requirements. Responsible party: Financial Aid Coordinator Planned completion date for corrective action plan: April 1, 2026 Plan to monitor completion of corrective action plan: Monthly meetings with the Workforce Finance Department will be held to review RT24 calculations, address discrepancies, and confirm ongoing compliance.

View Audit 396707

Finding 1205061 (2025-006)

Material Weakness 2025

School District of Polk County, Florida

FL

Student Financial Aid Eligibility Significant Deficiency

Return to Title IV Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education. Explanation of disagreement with audit finding: There is no disagreement wit...

Return to Title IV Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: The District will develop a letter in FOCUS that would automatically generate and notify all students when they are required to return funds to the Department of Education Responsible party: Financial Aid Coordinator, Workforce Finance Department Planned completion date for corrective action plan: April 30, 2026 Plan to monitor completion of corrective action plan: The Financial Aid Coordinator and Workforce Finance Department will conduct monthly reviews to confirm the automated notification process is functioning correctly and that required letters are being sent and documented.

View Audit 396707

Finding 1205060 (2025-005)

Material Weakness 2025

School District of Polk County, Florida

FL

Reporting Student Financial Aid Material Weakness

Common Origination & Disbursement Reporting Recommendation: We recommend the District evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disa...

Common Origination & Disbursement Reporting Recommendation: We recommend the District evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: Financial Aid Coordinators will monitor weekly to ensure matching of both systems. Responsible party: Financial Aid Coordinator and Administration Planned completion date for corrective action plan: April 1, 2026 Plan to monitor completion of corrective action plan: • The Financial Aid Coordinator will perform weekly reviews to confirm system alignment. • Administration will conduct quarterly oversight to ensure continued compliance and proper documentation.

View Audit 396707

Finding 1205059 (2025-004)

Material Weakness 2025

School District of Polk County, Florida

FL

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Title IV Credit Balances Recommendation: We recommend that the District review its policies and procedures for Title IV credit balances to ensure they are paid in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in resp...

Title IV Credit Balances Recommendation: We recommend that the District review its policies and procedures for Title IV credit balances to ensure they are paid in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: District has already implemented a plan by creating a drawdown process to ensure both the Financial Aid Coordinator and the Workforce Finance Department are in communication with each other. The drawdown process ensures that funds are received by the student in a timely manner (within 14 days) Responsible party: Financial Aid Coordinators, District Workforce Finance Department Planned completion date for corrective action plan: Task is completed Plan to monitor completion of corrective action plan: The Financial Aid Coordinator and Workforce Finance Department will hold monthly meetings to review the drawdown process and confirm continued compliance.

View Audit 396707

Corrective Action Plans

Filters