Corrective Action Plans

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Views of Responsible Officials: The College has noted that this finding may not align with the unique nature of our summer session, which has three terms included. There are four non-standard summer terms that do not follow the same reporting structure as the Fall and Spring Terms. The College inter...
Views of Responsible Officials: The College has noted that this finding may not align with the unique nature of our summer session, which has three terms included. There are four non-standard summer terms that do not follow the same reporting structure as the Fall and Spring Terms. The College interprets the 60-day reporting requirement to apply to the standard terms for Fall and Spring only. Historically, the college has reported summer enrollments in August, which has been treated as compliant by the Clearinghouse. However, after further review, the College will adjust its reporting schedule to align with recommendations from this finding. This adjustment will ensure that summer reporting aligns with the 60-day timeframe that is consistent with the Fall and Spring terms.
Finding 551122 (2024-001)
Significant Deficiency 2024
Name of contact person responsible for corrective action: Marguerite Lane, Associate Vice President Enrollment Management Mlane@molloy.edu 516-323-4014 Corrective action: Molloy University understands the finding and has devised a process to ensure that the correct withdrawal dat...
Name of contact person responsible for corrective action: Marguerite Lane, Associate Vice President Enrollment Management Mlane@molloy.edu 516-323-4014 Corrective action: Molloy University understands the finding and has devised a process to ensure that the correct withdrawal date is recorded National Student Loan Data System (NSLDS) with the 60-day window from the date of determination. In the finding, the withdrawals were reported within the window, but the effective dates reported were incorrect. We identified the issue and made the corrections, but the corrections were made outside the 60-day window. To address this, we will utilize our current practice of relying on error reports to address such errors, but we will run these reports at an increased frequency (bi-weekly) and have an additional staff member review the information. We will keep a file for each student withdrawal to show that our dates align in our system, the National Student Clearinghouse, and NSLDS within the required timeframe. Proposed Completion Date: March 31, 2025
Trinity College of Florida will develop, implement and maintain a written information security program in accordance with GLBA compliance
Trinity College of Florida will develop, implement and maintain a written information security program in accordance with GLBA compliance
Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University implement additional internal controls to ensure proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to separate...
Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University implement additional internal controls to ensure proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing training should be provided to financial aid staff on the importance of internal controls and compliance with Title IV regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office has expanded staffing and continues to provide ongoing training through NASFAA, NCASFAA, CFNC, and Ellucian. Roles and responsibilities are now clearly defined to ensure proper segregation of duties, and cross-training is underway to provide continuity during vacancies. These efforts support the implementation of enhanced internal controls and Title IV compliance. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: June 2025
Student Financial Assistance Cluster - Assistance Listing No. 84.268 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a proc...
Student Financial Assistance Cluster - Assistance Listing No. 84.268 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a process to maintain all reconciliations as support of performance monthly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Business Office will complete monthly reconciliations in addition to the reconciliation at the time of draw of federal funds to comply with federal requirements. Name(s) of the contact person(s) responsible for corrective action: Belinda Burke, VP for Finance and Administration, CFO Planned completion date for corrective action plan: April 2025
Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported timely. Explanation of disagreement with audit finding: There is no...
Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Department will evaluate its policies and procedures around reporting to the COD to ensure that student information is reported timely. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: April 2025
Student Financial Assistance Cluster - Assistance Listing No. No. 84.268 Recommendation: We recommend the University review its process around sending exit counseling information to students to ensure this information is received and the University is performing required procedures. Explanation of d...
Student Financial Assistance Cluster - Assistance Listing No. No. 84.268 Recommendation: We recommend the University review its process around sending exit counseling information to students to ensure this information is received and the University is performing required procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office has hired additional staff, enhanced training efforts, and established a standard procedure to send loan exit counseling notifications to students at the end of each term, ensuring regulatory compliance. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: June 2025
Student Financial Assistance Cluster - Assistance Listing No. No. 84.063 Recommendation: We recommend the University implement a review process to ensure calculations of Pell awards are using the correct information. Explanation of disagreement with audit finding: There is no disagreement with the a...
Student Financial Assistance Cluster - Assistance Listing No. No. 84.063 Recommendation: We recommend the University implement a review process to ensure calculations of Pell awards are using the correct information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To reduce calculation errors in Pell Grant awards, the Financial Aid Office has hired additional staff, increased training, and implemented an automated packaging system. This system ensures Pell award amounts are calculated using accurate and verified student information. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: August 2025
Student Financial Assistance Cluster - Assistance Listing No. No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Explanation of disagreement with audit fin...
Student Financial Assistance Cluster - Assistance Listing No. No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Information Technology Department will ensure its written information security program addresses the required minimum elements outlined in 16 CFR 314.4. Name(s) of the contact person(s) responsible for corrective action: Belinda Burke, VP for Finance and Administration, CFO Planned completion date for corrective action plan: April 2025
Student Financial Assistance Cluster - Assistance Listing No. 84.268 Recommendation: We recommend the University establish additional policies to ensure all students meet the financial need criteria before awarding Title IV funds. Explanation of disagreement with audit finding: There is no disagree...
Student Financial Assistance Cluster - Assistance Listing No. 84.268 Recommendation: We recommend the University establish additional policies to ensure all students meet the financial need criteria before awarding Title IV funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office has hired additional personnel to enhance oversight and processing capacity. Staff will continue to receive training and will review all late and supplemental awards to verify that students meet financial need criteria before Title IV funds are disbursed. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: June 2025
View Audit 352022 Questioned Costs: $1
Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review regulations to ensure the University understands the definitions for enrollment information required to be reported to the NSLDS. Explanation of...
Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review regulations to ensure the University understands the definitions for enrollment information required to be reported to the NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Given the findings related to enrollment reporting, the University will review policies and procedures to ensure information is reported in a timely and accurate manner. The University will review the NSLDS regulations and ensure understanding and compliance of the NSLDS definitions related to required reporting of enrollment changes. The University will verify program lengths for all active programs reported to NSLDS. The Registrar is the responsible party for enrollment reporting via NSC to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Lynda Szymanski, VP for Academic Affairs Planned completion date for corrective action plan: April 2025
Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University review the R2T4 requirements and ensure their process incorporates a review of students to ensure no calculations are missed that should be performed. Explanation ...
Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University review the R2T4 requirements and ensure their process incorporates a review of students to ensure no calculations are missed that should be performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: At the conclusion of each academic term, the Director of Financial Aid will review enrollment data with the Registrar’s Office to identify students who may require Return of Title IV (R2T4) calculations. Completion of all required R2T4 calculations will be documented and verified by the Director to ensure full compliance with federal guidelines. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: May 2025
Management agrees with the auditors and has initiated the necessary corrective action plan to mitigate the deficiency from occuring again. The plan is to implement new procedures to ensure the reporting to the NSLDS is done on a timely basis.
Management agrees with the auditors and has initiated the necessary corrective action plan to mitigate the deficiency from occuring again. The plan is to implement new procedures to ensure the reporting to the NSLDS is done on a timely basis.
Name of Responsible Individual: Brandon Rhone, Analyst, Financial Aid Systems, and Chad Wick, Director Financial Aid Corrective Action: The Vice President of Enrollment created a process, implemented in the Spring of 2023, that automated the student loan disbursement notifications with-in the requi...
Name of Responsible Individual: Brandon Rhone, Analyst, Financial Aid Systems, and Chad Wick, Director Financial Aid Corrective Action: The Vice President of Enrollment created a process, implemented in the Spring of 2023, that automated the student loan disbursement notifications with-in the required 30 days of student accounts transmitting their loans, but some of them were already disbursed before this new process. To further enhance this process the FA Analyst created a process in Colleague to automate this process as well as allow for us to keep better records of the notifications. This new process was implemented in 2024, and the University should see results on the 2024-2025 Audit. Anticipated Completion Date: March 31, 2025
Name of Responsible Individual: Montague Blount, Registrar Corrective Action: The University Registrar has worked to develop and implement a plan to ensure appropriate cross-training, position backup, and a system of proper checks and balances to improve quality control and continuity in executing ...
Name of Responsible Individual: Montague Blount, Registrar Corrective Action: The University Registrar has worked to develop and implement a plan to ensure appropriate cross-training, position backup, and a system of proper checks and balances to improve quality control and continuity in executing core functions within the Registrar's Office. To enhance our efforts on this front, the University Registrar will implement additional training measures and reporting SOPs to ensure all status changes and error records are submitted to the NSC/NSLDS website within the required timeframe. These efforts will strengthen accuracy and overall compliance with reporting requirements. Enrollment reporting remains a critical focus of this initiative. Anticipated Completion Date: June 30, 2025
Name of Responsible Individual: Mary Beth Schiller-Schwenke, Chief Financial Officer and Joyce Sawyer, Director of Payroll Services Corrective Action: The instance of non-compliance occurred during a period of software change for timecard recordkeeping. The former software allowed the supervisor to...
Name of Responsible Individual: Mary Beth Schiller-Schwenke, Chief Financial Officer and Joyce Sawyer, Director of Payroll Services Corrective Action: The instance of non-compliance occurred during a period of software change for timecard recordkeeping. The former software allowed the supervisor to electronically approve a student timecard after payroll was processed. The new software does not allow this and the process now requires manual follow-up and signature. The Payroll Office in combination with Human Resources will enhance training for supervisors and require additional training for those supervisors that fail to approve timecards timely. Reporting has been improved to identify timecards that have not been approved. A procedure change has been implemented to remove wages from FWS if the hours in question remain unapproved after 30 days. Anticipated Completion Date: March 31, 2025
Name of Responsible Individual: Mary Beth Schiller-Schwenke, Chief Financial Officer Corrective Action: The FWS Program instances were the result of retroactive award adjustments that posted subsequent to the federal draws and federal draw reconciliations. To prevent a similar error in the future, ...
Name of Responsible Individual: Mary Beth Schiller-Schwenke, Chief Financial Officer Corrective Action: The FWS Program instances were the result of retroactive award adjustments that posted subsequent to the federal draws and federal draw reconciliations. To prevent a similar error in the future, the Business Office has modified its draw recordkeeping process to require that the employees that perform the draw requests and the reconciliations review the FWS master worksheet for any pending adjustments. The Federal Pell Grant Program instances resulted from reversals of student awards. The Business Office routinely monitors the general ledger for award transactions, however, reversals of student aid awarded late in the academic term can be missed. The Financial Aid Office will be responsible to notify the Business Office when they initiate award reversals that necessitate a refund. In addition to ongoing monitoring of the related general ledger accounts, the Business Office will also create automated reporting to notify staff of the pending account balances. Anticipated Completion Date: March 31, 2025
Name of Responsible Individual: Brandon Rhone, Analyst, Financial Aid Systems, and Chad Wick, Director Financial Aid Corrective Action: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring of a new Director of Financial Aid. The University tr...
Name of Responsible Individual: Brandon Rhone, Analyst, Financial Aid Systems, and Chad Wick, Director Financial Aid Corrective Action: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring of a new Director of Financial Aid. The University transitioned from a manual awarding process to an automated process after last year’s audit but not in time to change some of the 23-24 awards. In the past FSEOG funds were used to assist students to pay off balances allowing them to register for the next semester. This practice in no longer being followed beginning with the 24-25 academic year. In addition, the Financial Aid office will review all 2024-2025 FSEOG awards to ensure that FSEOG is only awarded to Pell recipients. Anticipated Completion Date: March 31, 2025
Name of Responsible Individual: Chad Wick, Director Financial Aid Corrective Action: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. The newly hired staff did not receive the proper training to perform th...
Name of Responsible Individual: Chad Wick, Director Financial Aid Corrective Action: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors identifying and calculating the unearned amount of Title IV assistance to be returned. The previous Financial Aid Director was terminated before the prior corrective action plan could be fully completed. New leadership, in collaboration with the Office of Information Technology, developed an automated weekly report confirming student withdrawal dates for the 24-25 academic year. The report is emailed to Financial Aid director every Friday. The Financial Aid Director reviews the report and identifies Title IV recipients. The return of Title IV funds calculation is performed for those students. Any funds required to be disbursed or returned are then processed. Anticipated Completion Date: March 31, 2025
Name of Responsible Individual: Brian Emery, Associate Director Financial Aid and Chad Wick, Director Financial Aid Corrective Action: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director Financial of Aid. They also contracted w...
Name of Responsible Individual: Brian Emery, Associate Director Financial Aid and Chad Wick, Director Financial Aid Corrective Action: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director Financial of Aid. They also contracted with a third-party servicer that assisted with the verification process. The newly hired staff did not receive the proper training to perform their roles effectively. These two changes led to errors in verifying certain data when performing verification. The Financial Aid office implemented a Quality Assurance two-step verification process, but this took place after some of the 23-24 awards were processed. The Financial Aid office will run a report to identify all students selected for verification for 2024-2025 and review them for accuracy. If any corrections are needed, they will be updated, and awards will be adjusted as needed. Anticipated Completion Date: March 31, 2025
Individual Responsible for Corrective Action: Everett Jeter, Director of Compliance Corrective Action: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A loan disbursement notification was sent to the students i...
Individual Responsible for Corrective Action: Everett Jeter, Director of Compliance Corrective Action: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A loan disbursement notification was sent to the students in question; however, we can only document the loan disbursement notification was sent but are unable to document the date or content of the communication. Students identified with missing communications are from spring 2024. Our internal processes dictate that the notification would normally be sent on the date of disbursement. We will develop and implement a loan disbursement notification to loan recipient reconciliation process to effectively capture students with missing communications to ensure that both a record of the notification and the date are maintained. Anticipated Completion Date: August 15, 2025
Individual Responsible for Corrective Action: Debbie Gannon, Registrar Corrective Action: Certain students’ campus-level enrollment data was not accurately reported. The Registrar’s Office will determine why certain students falling outside of normal graduate submission schedules are not being cap...
Individual Responsible for Corrective Action: Debbie Gannon, Registrar Corrective Action: Certain students’ campus-level enrollment data was not accurately reported. The Registrar’s Office will determine why certain students falling outside of normal graduate submission schedules are not being captured in DegreeVerify files submitted to the National Student Clearinghouse. Manual submissions for these non-standard graduates will be performed until a reporting solution is identified. Anticipated Completion Date: August 15, 2025
Individual Responsible for Corrective Action: Everett Jeter, Director of Compliance Corrective Action: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The University correctly determined the amount of Title IV ai...
Individual Responsible for Corrective Action: Everett Jeter, Director of Compliance Corrective Action: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The University correctly determined the amount of Title IV aid earned for a student within the required timeframes, but due to administrative oversight, omitted one of the required awards from the return update on the student account. A regular review of R2T4 calculations will be developed to ensure that the actual returns match the return calculations. Anticipated Completion Date: August 15, 2025
Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), Director of Financial Aid (Dr. Ojebe Ifegwu), University Registrar (Charee Ellison) Corrective Action: The University concurs with the finding and will review and revise its procedures for the frequency of ...
Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), Director of Financial Aid (Dr. Ojebe Ifegwu), University Registrar (Charee Ellison) Corrective Action: The University concurs with the finding and will review and revise its procedures for the frequency of NSLDS reporting to ensure timely reporting of enrollment changes. The University will implement a monthly enrollment audit to ensure that any change in enrollment status is identified in a timely manner and reported to NSLDS. Anticipated Completion Date: June 30, 2025
Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), Director of Financial Aid (Dr. Ojebe Ifegwu), University Registrar (Charee Ellison) Corrective Action: The University concurs with the finding and will monitor internal controls to ensure that the return of...
Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), Director of Financial Aid (Dr. Ojebe Ifegwu), University Registrar (Charee Ellison) Corrective Action: The University concurs with the finding and will monitor internal controls to ensure that the return of Title IV funds is processed in accordance with federal regulations, specifically within the required 45-day timeframe after determining a student has withdrawn from the university. The university will establish a quarterly audit and monitoring system to review all Title IV fund returns, ensuring compliance with federal guidelines. Anticipated Completion Date: June 30, 2025
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