Corrective Action Plans

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November 21, 2025 FINDING 2025-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Otis College of Art and Design agrees with the finding. Upon review of the finding, Financial Aid administration met with Registrar’s staff to create a...
November 21, 2025 FINDING 2025-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Otis College of Art and Design agrees with the finding. Upon review of the finding, Financial Aid administration met with Registrar’s staff to create a new procedure whereby immediate reporting of withdrawals are made directly to NSLDS in addition to the regularly scheduled monthly reports to NSLDS through the National Student Clearinghouse (NSC). This immediate reporting should eliminate any timing issues with the monthly reports through NSC. In addition, a joint effort to streamline the routing of withdrawal forms to the appropriate departments for faster processing is underway. This reprocessing of the withdrawal forms will be implemented in the next 120 days. Responsible Office and Individuals The Executive Director of Financial Aid and The One Stop, Michaela Matsumoto and Registrar, Nicole Raef are the responsible individuals for implementation of the corrective action plan. Corrective Action Plan The Registrar implemented a centralized tracking system that is now used for every withdrawal and graduation status change at all points in the semester. Registration reviews the withdrawal list weekly to ensure each change is accurately reflected in both NSC and NSLDS. To address graduation status updates, we are adjusting the timeline of our final spring enrollment report to NSC so it is submitted at the end of May. This allows NSC to transmit the data to NSLDS at the beginning of June resulting in fewer manual updates in NSLDS. Registration will then review all graduated students to confirm accurate NSLDS reporting rather than relying solely on Clearinghouse submissions. In addition, the Registration office will review and correct the NSC error report on a monthly basis. The Financial Aid and Registration offices will also initiate quarterly meetings to ensure timely submissions and address any emerging issues.
The purpose of the Goods Receipt (GR) is to record receipt of goods or services as soon as they are delivered and verified to be in acceptable condition. A Goods receipt must be posted in SAP for all items actually received. Vendors submit invoice(s) referencing the purchase order (PO) directly to A...
The purpose of the Goods Receipt (GR) is to record receipt of goods or services as soon as they are delivered and verified to be in acceptable condition. A Goods receipt must be posted in SAP for all items actually received. Vendors submit invoice(s) referencing the purchase order (PO) directly to Accounts Payable after delivery, indicating that the goods or services have been provided and requesting payment. Accounts Payable then reviews the vendor invoice, purchase order, and goods receipt in SAP to perform the required three-way match (PO, GR, and vendor invoice) before processing payment. 1. The Accounts Payable team will collaborate with the Procurement Services Division to establish and implement a process that ensures the timely review and reconciliation of Goods Receipt (GR) entries. This will include the development of clear guidance / training materials for schools and offices to periodically review their GR balances. Training will be conducted via Virtual Office Hours on a quarterly basis for sites to make necessary adjustments when the goods or services received differ from the original Purchase Order (PO) or the corresponding invoice. 2. The Accounts Payable team will collaborate with the Procurement Services Division to develop supplemental documentation and guidance regarding proof of delivery for goods and services received. 3. Accounts Payable staff will receive ongoing training throughout the year on documentation and reconciliation requirements, particularly when new internal controls, procedures, and processes are created. Training will be incorporated into regular team meetings, procedural updates, and onboarding for new team members to maintain alignment and accuracy across the department. The implementation target date for the above corrective action plan is June 30, 2026. Name: Rocio Saucedo Title: Director of Accounts Payable Contact Information: Rocio.Saucedo@lausd.net
Views of responsible officials and planned corrective actions: The University agrees with the auditor's finding and recommendations. The following corrective action will be taken: The University has awarded aid in the amount of $3,729 to students which represents student earned aid from an updated R...
Views of responsible officials and planned corrective actions: The University agrees with the auditor's finding and recommendations. The following corrective action will be taken: The University has awarded aid in the amount of $3,729 to students which represents student earned aid from an updated R2T4 calculation accounting for the proper use of the withdrawal date, institutional charges and total aid for 2024-25 academic year. The University will review, and revise policies and procedures related to the return of funds calculation. Specifically, the University will:  Update procedures to include a review of input items by AVP prior to finalizing returns.  Provide training to relevant staff, including staff outside of the Office of Student Financial Assistance, on proper calculation methods to ensure compliance and accuracy of R2T4 calculations. The University is exploring opportunities to automate partially or completely the R2T4 process to support accurate and efficient processing and enhance compliance.
Corrective Action Plan - In order to ensure compliance with 34 CFR 685.309(2) and the 60 day reporting requirement for the students who cease to be enrolled half time by submission of an Intent Not to Return form, as well as, for those students who do not show up for a subsequent semester, the Insti...
Corrective Action Plan - In order to ensure compliance with 34 CFR 685.309(2) and the 60 day reporting requirement for the students who cease to be enrolled half time by submission of an Intent Not to Return form, as well as, for those students who do not show up for a subsequent semester, the Institution has changed the standard reporting transmission date from after the 3rd week of school in the subsequent term to 55 days after the last day of the previous term (approximately the 1st week of the term). This will ensure that all students that haven’t returned will be captured in the required 60 days reporting time. Additionally, we have made the process more user friendly for those involved by changing from script processing to Excel based reporting in an effort to make the data clean in a format that will allow visualization of processing errors. The Registrar will be responsible for ensuring the 60 day reporting requirements are met by setting up the annual transmission dates with clearinghouse for each term of the year by utilizing 55 days between the end of the term as the first reporting for the following period. This reporting requirement will be added to the internal audit completed the Financial Aid Office
Institutional Response The institution concurs with the auditor’s findings and affirms that this was an isolated occurrence. Due to an administrative error, the affected student enrollment reflected a combination of graduate and undergraduate courses. While the withdrawal process was fully executed ...
Institutional Response The institution concurs with the auditor’s findings and affirms that this was an isolated occurrence. Due to an administrative error, the affected student enrollment reflected a combination of graduate and undergraduate courses. While the withdrawal process was fully executed for the undergraduate courses, the graduate course remained active in the student information system, preventing the transaction from being recorded as a complete withdrawal. As part of the institution’s internal control and monitoring procedures, the discrepancy was detected and promptly corrected. A Return of Title IV (R2T4) calculation was performed in accordance with federal regulations. The institution remains committed to continuous improvement and regulatory compliance. Additional staff training and process reviews have been implemented to strengthen internal controls and prevent similar occurrences in the future. Corrective Action Plan To strengthen compliance and prevent recurrence, the Miami campus has implemented the Degree Audit functionality in Ellucian Colleague. This enhancement ensures that all course enrollments, term dates, and institutional charges are accurately reflected in the system, allowing the R2T4 process to operate with complete and consistent data. The R2T4 reports are already in place, and staff training, along with improved communication among Student Services and Finance offices, will reinforce timely and accurate processing. Implementation of the Degree Audit at the San Juan campus will follow the completion of a curricular change currently under development by the Academic Department. In the meantime, the San Juan campus continues to apply stricter procedures, such as requiring program director authorization before students enroll in courses outside their academic program. Anticipated completion date Immediately Name(s) of the Contact Person(s) Responsible for the Corrective Action Plan Mrs. Ileana Santiago, Controller Dr. Antonio Llorens, CIO
Institutional Response The institutions agree with the auditor. This was an isolated case of the roster. The institution concurs with the auditor’s finding. We acknowledge the delay in issuing one refund beyond the required 14-day timeframe. Although this was an isolated occurrence, the University i...
Institutional Response The institutions agree with the auditor. This was an isolated case of the roster. The institution concurs with the auditor’s finding. We acknowledge the delay in issuing one refund beyond the required 14-day timeframe. Although this was an isolated occurrence, the University is committed to strengthening its internal controls and leveraging technology to prevent recurrence and ensure full compliance with federal regulations. Corrective Action Plan The institution is enhancing automation, monitoring, and accountability to ensure compliance with the 14-day refund requirement. Using Ellucian Colleague’s ODS/Informer, new reports will track Title IV credit balances and flag accounts exceeding 10 days without a refund as a preventive control. These reports will run weekly or more frequently to maintain proactive oversight. A dedicated staff member in the Student Accounts Office will be specifically assigned to process refunds within the required timeframe, ensuring clear accountability and preventing delays. The Finance organizational chart and staff assignment are under review, with the final assignment to be completed by December 1, and the reports are expected to be running by November 3. Anticipated completion date December 1, 2025 Name(s) of the Contact Person(s) Responsible for the Corrective Action Plan Mrs. Ileana Santiago, Controller Dr. Antonio Llorens, CIO
The financial aid office is under new leadership as of January 1, 2025. During 2025, department leadership began its review of departmental policies and procedures, focusing on remediating compliance weaknesses within the department while moving toward best practice in federal and state aid delivery...
The financial aid office is under new leadership as of January 1, 2025. During 2025, department leadership began its review of departmental policies and procedures, focusing on remediating compliance weaknesses within the department while moving toward best practice in federal and state aid delivery. Department leadership has put structures in place at multiple points of potential failure to prevent inaccurate aid calculations. These structures include new policy and procedure documentation, enhanced optimization in the Banner system, staff training in multiple modalities including intradepartmental training, asynchronous independent training, off-site training, and a monthly reconciliation program with AVC’s fiscal office. We have also begun a system of cross training to ensure that expertise persists within the department during times of staffing changes, extended leaves of absence, and vacancies.
Condition & Criteria: The College did not consistently report Direct Loan and Pell Grant origination/disbursement records to the COD system within the required 15-day window (or November 30, 2024 deadline), due to EDConnect software and system issues. Auditor's Recommendation: Implement additional p...
Condition & Criteria: The College did not consistently report Direct Loan and Pell Grant origination/disbursement records to the COD system within the required 15-day window (or November 30, 2024 deadline), due to EDConnect software and system issues. Auditor's Recommendation: Implement additional processes to ensure timely reporting and prompt resolution of software issues. Corrective Action: The Financial Aid department is implementing automated alerts and conducting weekly compliance checks to ensure timely and accurate processing. The team is coordinating closely with TVCC IT to prevent future delays, and software or system performance issues affecting financial aid operations will be escalated as a priority. In addition, staff will receive training on federal reporting timelines and established escalation protocols to strengthen long-term compliance. Responsible person: Director of Financial Aid, with oversight from Vice President of Student Services. Anticipated Completion Date: Begin implementation immediately and accomplish full implementation by Spring 2026; ongoing monitoring.
Corrective action taken or planned: Management concurs with the finding and the auditor's recommendation. The District will continue to provide targeted training and perform ongoing monitoring of staff responsible for the preparation and review of R2T4 calculations. In addition, the campus will crea...
Corrective action taken or planned: Management concurs with the finding and the auditor's recommendation. The District will continue to provide targeted training and perform ongoing monitoring of staff responsible for the preparation and review of R2T4 calculations. In addition, the campus will create internal procedures for the new FAFSA simplification calculations. District will strengthen internal controls over the R2T4 process by implementing an additional level of supervisory review and approval to ensure calculations are performed accurately and in accordance with applicable federal regulations. Anticipated completion date: June 30, 2026 Contact person responsible: Melissa Raby Vice President, Student Services Columbia College
The University initiated the following remedial actions upon self-identification of the items described in the finding. 1. Updated its policies to specifically prohibit any form of compensation (including payment of bonuses and other forms of incentive compensation) or promotions for admissions depa...
The University initiated the following remedial actions upon self-identification of the items described in the finding. 1. Updated its policies to specifically prohibit any form of compensation (including payment of bonuses and other forms of incentive compensation) or promotions for admissions department personnel to be based on the achievement of enrollment goals. 2. Discontinued the prior practice of awarding office-wide bonuses for undergraduate admissions personnel. 3. Engaged higher-education industry compliance experts to consult and assist the University with the development and implementation of stronger policies and procedures in the area of personnel compensation philosophy, including job levels and standardized promotional criteria. 4. Certain management-level employees responsible for oversight of enrollment recruitment and human resources departments within the University are no longer employed by the University. 5. Enhanced competencies of its internal compliance department and strengthened the program structure and operating model, supporting improved communication and oversight.
Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: Pertinent financial aid staff will perform additional training on R2T4 regulations and implement a second review on R2T4 calculations performed. Additionally, financial aid staff will work with the staff in Online Learning Office ...
Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: Pertinent financial aid staff will perform additional training on R2T4 regulations and implement a second review on R2T4 calculations performed. Additionally, financial aid staff will work with the staff in Online Learning Office of Academic Affairs to retain academic activity for all distance education students without passing grades. Person Responsible for Corrective Action Plan: Tim Sechrist, Director of Financial Aid Anticipated Date of Completion: January 31, 2026
The delay occurred because the responsibility for processing was temporarily reassigned to another employee who had not yet received full training on the procedure. The task has been reassigned to the original staff member who has extensive experience with R2T4 processing. In addition, the Financial...
The delay occurred because the responsibility for processing was temporarily reassigned to another employee who had not yet received full training on the procedure. The task has been reassigned to the original staff member who has extensive experience with R2T4 processing. In addition, the Financial Aid Office will cross train multiple Financial Aid Specialist on the processing and tracking of R2T4 to ensure compliance and remove any delays in processing. All calculations are now being completed in compliance with federal regulations, and we have implemented measures to ensure timely processing moving forward.
Federal Award Finding Number: 2025-001. Planned Corrective Action: Enhance procedures over the NSLDS system to ensure accurate and timely reporting moving forward. Anticipated Completion Date: June 30, 2026 Responsible Contact Person: George Mastoridis, Director of First Coast Technical College and ...
Federal Award Finding Number: 2025-001. Planned Corrective Action: Enhance procedures over the NSLDS system to ensure accurate and timely reporting moving forward. Anticipated Completion Date: June 30, 2026 Responsible Contact Person: George Mastoridis, Director of First Coast Technical College and Elizabeth Moore, Director of Accounting
U.S. Department of Education 2025-001: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During our testing of enrollment status reporting, we noted the change in enrollment status was not reported within 60 day...
U.S. Department of Education 2025-001: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During our testing of enrollment status reporting, we noted the change in enrollment status was not reported within 60 days. Recommendation: We recommend Hagerstown Community College reevaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid has contacted the National Student Clearinghouse (NSC) to assess whether any errors occurred during the file transmission process. As of the date of this submission, HCC has not received a response from NSC. Upon receipt of NSC’s findings, HCC will work collaboratively with NSC to identify the root cause of the error and implement corrective actions to prevent recurrence. HCC will continue to perform periodic spot checks of student records transmitted to NSC and subsequently reported to the National Student Loan Data System (NSLDS). Any discrepancies identified through these reviews will be addressed through coordinated corrective action by the Financial Aid, Registrar, and Institutional Effectiveness offices to ensure data accuracy and regulatory compliance. Name(s) of the contact person(s) responsible for corrective action: Dr. Charles M. Scheetz, Director of Financial Aid and W. Christopher Baer, Registrar Planned completion date for corrective action plan: June 30, 2026
Name of Contact Person: Tammy Sanders, Controller, tammy.sanders@pacificu.edu Corrective Action Planned: Pacific University acknowledges the importance of an effective control environment. Management will implement proper reviews of disbursement notices to ensure timeliness and completeness. Anticip...
Name of Contact Person: Tammy Sanders, Controller, tammy.sanders@pacificu.edu Corrective Action Planned: Pacific University acknowledges the importance of an effective control environment. Management will implement proper reviews of disbursement notices to ensure timeliness and completeness. Anticipated Completion Date: January 31, 2026 Statement of Concurrence or Nonconcurrence: Pacific University management agrees with the finding.
2025-002 Federal Program - Student Financial Assistance Cluster -Assistance Listing Nos. 84.063, Federal Pell Grant Program and 84.268 Federal Direct Student Loans U.S. Department of Education Program Year 2024-2025 - Enrollment Reporting Finding Summary: The University is required to report enrollm...
2025-002 Federal Program - Student Financial Assistance Cluster -Assistance Listing Nos. 84.063, Federal Pell Grant Program and 84.268 Federal Direct Student Loans U.S. Department of Education Program Year 2024-2025 - Enrollment Reporting Finding Summary: The University is required to report enrollment information to the National Student Loan Data System (NSLDS) when changes occur related to enrollment statuses, program information, and effective dates within a specified time. Recommendation: The University should establish controls designed to facilitate accurate reporting of students' enrollment information to NSLDS within the required time frame. Additionally, the University should enhance controls addressing circumstances in which students unofficially withdraw. Action taken in response to finding: The Office of Registrar implemented a revised end-of-term procedure. Effective immediately, all students who are unofficially withdrawn for the semester- defined as students who have failed all courses or have a combination of official withdrawcJls and fa ilures for all enrolled courses- will have their enrollment status manually updated to withdrawn in the National Student Clearinghouse (NCS) reporting process, which from there is reported to NSLDS. In addition, the Office of Registrar will provide to the Office of Financial Aid a list of these students at the end of each term. This will allow Financial Aid to verify that NSC updates NSLDS accurately and within the required reporting timeframe . To prevent the issue of timely reporting, the Registrar's Office has implemented a reconciliation check to ensure that graduate counts are consistent across both NSC reports and align with internally generated graduate lists prior to submission. Name(s) of the contact person(s) responsible for corrective action: Alaina Abolail Planned completion date for corrective action plan: January 1, 2026
2025-001 Federal Program - Student Financial Assistance Cluster - Assistance Listing Nos. 84.063, Federal Pell Grant Program and 84.268 Federal Direct Student Loans U.S. Department of Education Program Year 2024-2025 - Return of Title IV Funds Finding Summary: The University is responsible for calcu...
2025-001 Federal Program - Student Financial Assistance Cluster - Assistance Listing Nos. 84.063, Federal Pell Grant Program and 84.268 Federal Direct Student Loans U.S. Department of Education Program Year 2024-2025 - Return of Title IV Funds Finding Summary: The University is responsible for calculating and determining the amount ofTitle IV aid earned by a student when they withdraw from the institution during a payment period and identifying if a post-withdrawal disbursement is applicable. The University is responsible for returning any unearned aid within the required time frame outlined by 34 CFR 668.173(b). Recommendation: The University should establish controls designed to support accurate review of Title IV fund calculation and timely return of funds within the required time frame. Action taken in response to finding: The Office of Financial Aid has established a procedure when the dates are being set for the award year, the term's start date, end date, and consecutive break periods will be submitted to the Provost and Vice President for Academic Affairs for review and approval. A copy of the reviewed and approved dates will be retained within Financial Aid. The Office of Financial Aid also established, internally, an electronic tracking list for Return to Title IV, which will capture post withdrawal offers. Within the list the date of the student's notification is noted, along with the due date of post withdrawal loan acceptance offers. Finally, the Office of Financial Aid established, internally, an electronic tracking list for officially and unofficially withdrawn students. All students reported to the Financial Aid Office as withdrawn are placed on this list to track their progress form initial reporting to Financial Aid, date assigned to the counselor, receipt of R2T4 calculation or date of determination that the calculation is not required in the case of the students not using Title IV awards, reporting date to Common Organization & Disbursement (if applicable), and reporting date of adjustments sent to Bursar Office. Name(s) of the contact person(s) responsible for corrective action: Jason Reavis Planned completion date for corrective action plan: January 1, 2026
2025-002: Student Financial Audit Cluster - Special Tests: Return of T itle IV Funds and NSLDS Reporting Anticipated completion date: done - June 18, 2025 Contact person: Brandi Payne Cervera Corrective actions: The two late aid returns were made under the following circumstances. Student's effectiv...
2025-002: Student Financial Audit Cluster - Special Tests: Return of T itle IV Funds and NSLDS Reporting Anticipated completion date: done - June 18, 2025 Contact person: Brandi Payne Cervera Corrective actions: The two late aid returns were made under the following circumstances. Student's effective date of the withdrawal was March 25, 2025. However, the withdrawal was not processed in our Colleague system until April 9, 2025. The backdated effective date of the withdrawal in Colleague did not appear on our enrollment activity report that is used to identify complete withdrawals because this report is run weekly using a defined date range. As a result, the student's withdrawal was not identified in a timely manner. The withdrawal was identified by our Assistant Director upon her review of students with all non-passing grades at the end of the semester prior to the audit testing (see existing procedure/internal control below). The return-of-funds was processed as soon as the withdrawal was discovered, but it was out of the 45-day required timeframe. We have implemented a new procedure, as follows. New procedure (backdated withdrawal): The Registrar's Office will immediately notify Financial Aid of any withdrawals received by the Registrar's Office that require a backdated effective date in Colleague to ensure that we are returning funds within the required timeframe. The Financial Aid Director, Assistant Director of Financial Aid, and the Registrar met and developed this new procedure. The procedure was implemented on June 18, 2025. An institution must certify enrollment information to the National Student Loan Data System (NSLDS) every 60 days. Because of the issue with the backdated effective date of the withdrawal described above, the enrollment reporting for this student was made outside of the 60-day reporting window. I request the removal of the NSLDS reporting deficiency since the late processing of the student's withdrawal and return-of-funds was the root cause of the late NSLDS reporting, and there were no other enrollment reporting issues. The second late return was due to human error. After a R2T4 calculation has been performed, there is an "Update Student Aid" button on the ROFC screen in Colleague that must be manually marked "yes" in order for the return of- funds to post to the student's account. This step was missed for one student which caused the late return-of-funds outside of the required 45-day timeframe. New procedure (human error): Assistant Director has put a standing item on her calendar to review RT24's every Wednesday with a notation to check the "Update Student Aid" box in Colleague so that the return will occur. The Assistant Director will also check the list of withdrawals after each weekly aid transmittal to make sure the aid returns have all posted to the student accounts as expected. This procedure was put into place on June 18, 2025. Existing Procedure/Internal Control: We can say with certainty that out of the 165 withdrawals for the 2024/2025 award year, the two students identified in the audit were the only two late returns. The Assistant Director of Financial Aid reviews all students with non-passing grades at the end of each semester to identify unofficial withdrawals and to ensure that all returns were made appropriately and that no R2T4 calculations were missed. Potential issues are identified through this end-of-semester review. This is how the issue with the backdated withdrawal date described above was discovered. She will continue this effective internal control process each semester which will confirm that our new procedures are working as intended.
2025-001 Student Financial Aid Cluster- Reporting Anticipated completion date: Done Contact person: Nola Rocha Corrective actions: The incorrect inclusion of non-credit course data for new programs in the annual FISAP report resulted from a misinterpretation of reporting criteria. This isolated erro...
2025-001 Student Financial Aid Cluster- Reporting Anticipated completion date: Done Contact person: Nola Rocha Corrective actions: The incorrect inclusion of non-credit course data for new programs in the annual FISAP report resulted from a misinterpretation of reporting criteria. This isolated error affected one reporting element within an otherwise accurate submission. The issue was promptly addressed through clarification of FISAP guidance, staff retraining, and updates to procedural documentation and review checklists to ensure non-credit course activity is properly excluded in future reports. While the dollar amount could be viewed as measurable the financial reporting would not result in any financial impact, as the Department of Education allocates Campus-Based Program funds based on institutional requests and does not provide allocations in excess of those requests.
Finding Number: 2025-001 Condition: There was a lack of internal controls in place related to the return of Title IV funds. Planned Corrective Action: The College has implemented procedures to verify that academic dates are entered accurately in Banner and confirmed by personnel other than those res...
Finding Number: 2025-001 Condition: There was a lack of internal controls in place related to the return of Title IV funds. Planned Corrective Action: The College has implemented procedures to verify that academic dates are entered accurately in Banner and confirmed by personnel other than those responsible for calculating and reviewing returns of Title IV funds. This should ensure the related calculations are complete and accurate, and the funds are returned in a timely manner. Contact person responsible for corrective action: David Cummins, Vice President for Administrative Services and College Treasurer Anticipated Completion Date: December 2025
Management’s View and Corrective Action Plan: This finding has been corrected. In addition, the College has already taken corrective action to prevent this error from occurring again. First, when processing R2T4 calculations for students who populate on the end of term Failure to Pass report, studen...
Management’s View and Corrective Action Plan: This finding has been corrected. In addition, the College has already taken corrective action to prevent this error from occurring again. First, when processing R2T4 calculations for students who populate on the end of term Failure to Pass report, students with a withdrawal date in the first two weeks of a term, will be cross checked with the Registrar’s Office to ensure that the correct LDA is being used for R2T4 calculations. The report will not automatically be assumed as correct. In addition, the Instructional Dean has been notified and informed the faculty of this error and the processes for reporting LDAs have been reiterated. In addition, to the ARGOS report used during the 2024/2025 academic year, the Financial Aid Director is using a more detailed report that is available through the ACCS. The new report and the old report will be cross-checked for accuracy. We will continue to review and modify policies to ensure that R2T4 calculations are correct.
Management’s View and Corrective Action Plan: The College is in the process of correcting this finding for future withdrawals. The College Registrar’s Office reports enrollment, which includes withdrawal’s, every 30 days. However, this finding has to do with the Failure to Pass report and incorrect ...
Management’s View and Corrective Action Plan: The College is in the process of correcting this finding for future withdrawals. The College Registrar’s Office reports enrollment, which includes withdrawal’s, every 30 days. However, this finding has to do with the Failure to Pass report and incorrect LDA’s that are reported by the Instructional side of the College and indicating these dates in Banner. There are several places that LDA’s have to be updated and if one is missed it could affect the date that pulls on the Financial Aid Office’s Failure to Pass report. The Financial Aid Director and the College Registrar have already been working to ensure the accuracy of those dates for the Fall 2025 report. In addition, the Instruction Dean has been notified and informed the faculty of this error and the processes for reporting LDAs have been reiterated. The College will continue to improve the accuracy of this process.
2025-002: Late Return of Title [V Financial Aid - Student Financial Aid Cluster - Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2025 Condition Found During our Return of Title [V Fund testing, we noted that the College did not calculate or return Title IV ...
2025-002: Late Return of Title [V Financial Aid - Student Financial Aid Cluster - Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2025 Condition Found During our Return of Title [V Fund testing, we noted that the College did not calculate or return Title IV Student Financial Aid for two out of twenty-five students tested until after 45 days when the ryan student ceased attendance. We consider the untimely calculation and Return of Title TV Student Financial Aid to be an instance of noncompliance relating to the Special Tests and Provisions Compliance Requirement. This is a repeat finding of prior year Finding 2024-001. Corrective Action Plan To strengthen compliance with R2T4 timelines, the Financial Aid Office has implemented enhanced monitoring and workflow procedures. Responsibility for the weekly review and processing of R2T4 calculations has been reassigned to the Coordinator of Student Loans, ensuring consistent oversight and timely completion of required actions. Meetings are held every Wednesday to address any cases requiring follow-up creating a checkpoint to prevent delays. Responsible Person for Corrective Action Plan Coordinator of Student Loans Executive Director of Financial Aid Implementation Date of Corrective Action Plan 10/01/2025
2025-001 Federal Work Study - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2025 Condition Found During our Federal Work Study testing, we selected twenty-five students and noted that one student was paid for hours they did...
2025-001 Federal Work Study - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2025 Condition Found During our Federal Work Study testing, we selected twenty-five students and noted that one student was paid for hours they did not work and was overpaid $420. The College did not review federal work study hours worked against class hours scheduled and timesheets to ensure the student was not working during a scheduled class and that they were paid for the correct number of hours. We consider this condition to be an instance of non-compliance to the Eligibility compliance requirement. Corrective Action Plan The Financial Aid Department is collaborating with Career Services to implement improved oversight and training for Federal Work-Study. This includes required online training for both student employees and their supervisors, which must be completed prior to hiring any student employees within a department. Additionally, a campus-wide Standard Operating Procedure (SOP) has been developed, along with a Quick Guide for Supervisors of Student Employees, to ensure consistent processes and expectations related to scheduling, timesheet review, and compliance. Responsible Person for Corrective Action Plan Program Manager — Student Employment/Veteran Affairs Director of Career Services and Job Placement Implementation Date of Corrective Action Plan 08/22/2025
Claremont Graduate University Corrective Action Plan For the Fiscal Year Ended June 30, 2025 U.S. Department of Education FINDING 2025-001 – Special Tests and Provisions-Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Condition – During the audit fieldwork, a sample ...
Claremont Graduate University Corrective Action Plan For the Fiscal Year Ended June 30, 2025 U.S. Department of Education FINDING 2025-001 – Special Tests and Provisions-Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Condition – During the audit fieldwork, a sample of 20 federal aid recipient students were selected by auditors from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2024-2025 academic year. The enrollment information and withdrawal, address change, or graduation date per the University’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 20 students who had a change in address, graduated, or withdrew, there were four student files with errors. There was one student file that had incorrect enrollment status reported and not reported within the required timeframe. A second student file was reported under the incorrect enrollment status but within the appropriate time requirement. Lastly, two additional student files were not reported within the required timeframe. Explanation of Deficiency On June 20, 2025, the Degree Verify transmission to the National Student Clearinghouse (NSC) failed. Additionally, an error was identified that caused all international student records to be rejected. In order to correct the omission of international students, the monthly transmission was temporarily stopped until the issue could be resolved. This process took longer than anticipated. While degree records were being manually updated in NSC, staff were not aware that the enrollment records also needed to be separately updated. The Degree Verify file had been configured with a flag that should have automatically updated enrollment records upon submission, but this was not recognized at the time. As a result, a sample of student files reviewed contained reporting errors related to incorrect enrollment statuses or reporting delays. These issues would have been avoided if regularly scheduled reports had been submitted to NSC without interruption. Corrective Action Plan To address these deficiencies and prevent recurrence, the following corrective measures have been implemented: 1. Resumption of Scheduled Transmissions – The Office of Information Technology has corrected the Degree Verify file rejection issue. Monthly transmissions of Degree Verify reports will resume beginning September 20, 2025. 2. Enhanced Enrollment Reporting Schedule – Enrollment reporting has been rescheduled to occur every three weeks throughout each term, ensuring that enrollment status changes are reported to NSC and NSLDS within required timeframes. 3. Manual Record Reconciliation – A comprehensive review of late degree conferrals has been completed. All enrollment records have been manually updated in NSC to align with the corresponding degree records. 4. Staff Training and Awareness – The Registrar’s Office staff have been trained on the functional differences between degree reporting and enrollment reporting. Emphasis was placed on the need to verify that enrollment records are updated when degree records are manually corrected. 5. Monitoring and Quality Control – A reconciliation process has been established between the Registrar’s Office and OIT to confirm the successful transmission and acceptance of NSC files. Reports of any rejected records will be reviewed within five business days and promptly corrected. Contact Person Responsible: Vannessa Alvarado, Registrar 909-621-8285 Anticipated/Projected Completion Date: Manual corrections completed on September 3, 2025. Automated processes to projected September 20, 2025.
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