Corrective Action Plans

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Effect: Noncompliance with federal compliance requirements and errors that may affect determinations that guarantors, lenders, and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules.
Effect: Noncompliance with federal compliance requirements and errors that may affect determinations that guarantors, lenders, and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules.
Recommendation: The College should ensure all pertinent staff are sufficiently trained and knowledgeable on the requirements of the Enrollment Reporting requirements. Additionally, the College should revise current or implement new policies and procedures to strengthen its controls to ensure that al...
Recommendation: The College should ensure all pertinent staff are sufficiently trained and knowledgeable on the requirements of the Enrollment Reporting requirements. Additionally, the College should revise current or implement new policies and procedures to strengthen its controls to ensure that all status changes are reported accurately and in a timely manner to NSLDS.
Planned Corrective Action Responsible Official:
Planned Corrective Action Responsible Official:
To correct the issue and prevent recurrence, the College Registrar's Office is taking the following actions:
To correct the issue and prevent recurrence, the College Registrar's Office is taking the following actions:
1. Standardize data and dates used for reporting.
1. Standardize data and dates used for reporting.
The Registrar's Office will rely solely on the official enrollment and withdrawal status fields and dates recorded in Banner as the source for all enrollment reporting to the National Student Clearinghouse (NSC) and subsequently NSLDS. Internal lists, such as graduation lists or ad hoc reports, will...
The Registrar's Office will rely solely on the official enrollment and withdrawal status fields and dates recorded in Banner as the source for all enrollment reporting to the National Student Clearinghouse (NSC) and subsequently NSLDS. Internal lists, such as graduation lists or ad hoc reports, will no longer serve as the primary source for effective dates. For students identified in the audit sample, the registrar will review and correct NSLDS records to ensure that status codes and effective dates align with the official institutional records.
2. Tighten the roster submission and response schedule.
2. Tighten the roster submission and response schedule.
The college will ensure that roster files received from NSLDS (via NSC) are reviewed and certified in accordance with federal requirements no less frequently than every 60 days and that responses are transmitted within 15 days of receipt. Internally, the Registrar's Office will work on a more freque...
The college will ensure that roster files received from NSLDS (via NSC) are reviewed and certified in accordance with federal requirements no less frequently than every 60 days and that responses are transmitted within 15 days of receipt. Internally, the Registrar's Office will work on a more frequent submission rhythm during active terms (e.g., mid-term and end-of-term cycles) to avoid delays like those noted in the finding.
3. Automate and streamline withdrawal/status processing.
3. Automate and streamline withdrawal/status processing.
In coordination with Information Technology, the Registrar's Office is refining Banner SaaS workflows so that withdrawals and other status changes (e.g., reductions to less than half­time) are consistently captured in the system and reflected in the next enrollment reporting file, without manual int...
In coordination with Information Technology, the Registrar's Office is refining Banner SaaS workflows so that withdrawals and other status changes (e.g., reductions to less than half­time) are consistently captured in the system and reflected in the next enrollment reporting file, without manual intervention where possible. This includes validating that students who attend and withdraw in the same term are correctly reflected as withdrawn in NSLDS, rather than remaining in a prior status.
4. Retrospective review and clean-up of recent terms.
4. Retrospective review and clean-up of recent terms.
The Interim Registrar will conduct a targeted review of enrollment records for the periods impacted by the system transition (including FY 2024-2025), comparing Banner to NSC/NSLDS data. Any discrepancies (missing withdrawals, incorrect dates, "L-Less than Half-time" where a withdrawal occurred, "Z-...
The Interim Registrar will conduct a targeted review of enrollment records for the periods impacted by the system transition (including FY 2024-2025), comparing Banner to NSC/NSLDS data. Any discrepancies (missing withdrawals, incorrect dates, "L-Less than Half-time" where a withdrawal occurred, "Z-No Record Found," or outdated records) will be corrected through updated files and/or NSLDS Enrollment Maintenance.
5. Written procedures, staff training, and ongoing monitoring.
5. Written procedures, staff training, and ongoing monitoring.
The College is updating its written procedures for Enrollment Reporting to clearly document:
The College is updating its written procedures for Enrollment Reporting to clearly document:
o The Banner fields and dates that must be used for enrollment and withdrawal reporting;
o The Banner fields and dates that must be used for enrollment and withdrawal reporting;
o The required timing for responding to NSLDS roster files; and
o The required timing for responding to NSLDS roster files; and
o The steps for making corrections when errors are identified.
o The steps for making corrections when errors are identified.
These actions are either already underway or will be implemented in the current fiscal year to fully resolve the finding and ensure ongoing compliance with the Federal Enrollment Reporting requirements.
These actions are either already underway or will be implemented in the current fiscal year to fully resolve the finding and ensure ongoing compliance with the Federal Enrollment Reporting requirements.
Name: Steven Aguilar
Name: Steven Aguilar
Title: Financial Aid Director
Title: Financial Aid Director
Anticipated Completion Date:
Anticipated Completion Date:
Corrective Action Plan 2025-001: We acknowledge the overaward of Direct Subsidized Loans and underaward of Unsubsidized Loans for both students identified in the finding. Based on the guidance in Volume 8, Chapter 3 of the 2024-2025 Federal Student Aid Handbook which states “If you discover that a s...
Corrective Action Plan 2025-001: We acknowledge the overaward of Direct Subsidized Loans and underaward of Unsubsidized Loans for both students identified in the finding. Based on the guidance in Volume 8, Chapter 3 of the 2024-2025 Federal Student Aid Handbook which states “If you discover that a student received Direct Subsidized Loan funds in excess of financial need after the student is no longer enrolled for the loan period, you are not required to take any action to eliminate the excess subsidized loan amount.” We have not adjusted the student’s loan awards given the identification of the overaward took place after the end of the loan period for each student. As the University has closed after August 15, 2025, no additional actions are considered necessary. Completion Date: August 2025 Contact Person: Ann Spall, Chief Financial Officer
Finding: 2025-001 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.038, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: Under 34 CFR 690.63 and 685.200, institutions must calculate Pell grant and federal direct...
Finding: 2025-001 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.038, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: Under 34 CFR 690.63 and 685.200, institutions must calculate Pell grant and federal direct loan awards based on the student’s eligible enrollment status, cost of attendance, expected family contribution (EFC) or student aid index (SAI), satisfactory academic progress, and other Title IV eligibility requirements. Institutions are required to ensure award amounts are accurate and supported by the documentation in the students’ file. During testing of 60 students, it was found that two students who were not awarded the correct amount of Pell, one student who was not awarded the correct amount of federal direct loans, and two students who received subsidized direct loans however did not meet the requirements to receive the need-based aid. Responsible Individuals: Kella Helyer, Director of Financial Aid Corrective Action Plan: Management agrees with this finding. Banner reports have been modified to ensure that all students who are over gross need and over unmet need are captured in the report for the counseling team to review and update as needed. Anticipated Completion Date: February 16, 2026
Contact Person: Travis Mickey, Registrar Views of Responsible Officials and Planned Corrective Action: There is no disagreement with the audit finding. The College will collaborate with NSC to evaluate the errors in the file transmissions and to develop procedures to minimize further errors in the f...
Contact Person: Travis Mickey, Registrar Views of Responsible Officials and Planned Corrective Action: There is no disagreement with the audit finding. The College will collaborate with NSC to evaluate the errors in the file transmissions and to develop procedures to minimize further errors in the future. More specifically, the College will review the reporting procedures for withdrawn and graduating students to ensure the correct information is transmitted to NSLDS. Anticipated Completion Date: 6/30/2026
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