Corrective Action Plans

Finding 544776 (2024-002)

Significant Deficiency 2024

PA

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

2024-002 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding:...

2024-002 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: While the Office of Financial Aid has revamped how it manages exit notices and has made an improvement, our report has failed to pick up students that went from undergraduate to graduate in consecutive semesters. We will develop and implement a new report to ensure that this population is picked and exit notices are sent in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Jossie Johnson, Director of Financial Aid, and Micheal Reig, Registrar Planned completion date for corrective action plan: June 30, 2025

View Audit 351264

Finding 544706 (2024-002)

Significant Deficiency 2024

Tabor College, Inc.

KS

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Criteria or Specific Requirement - The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the chang...

Criteria or Specific Requirement - The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition - We noted discrepancies in the data reported in NSLDS compared to the data in the College’s records. Cause - The College’s processes and controls did not ensure that the effective dates were properly reported to NSLDS. Effect or potential effect - The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Questioned costs - None Context - During our testing, we noted for three out of eleven students tested, the program begin date per the institution did not match the student's effective date reported to NSLDS. In addition, we noted for one out of eleven students tested the notification was not made within 60 days. Sampling was not a statistically valid sample. Identification as a repeat finding, if applicable - 2023-003 Recommendation - We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials and planned corrective actions - Management concurs with the findings and recommendations. See separate report for planned corrective actions. Views of Responsible Officials and Corrective Action Plan – Management concurs with the findings and recommendation. Responsible personnel will review current guidance available from the Department of Education website and develop internal procedures to ensure timely compliance. This plan will include personnel and responsibility redundancy to account for employee absences or turnover, and a continuous review of available guidance to ensure the College stays current with any changes to this guidance. Additionally, monthly reconciliations have been added to the College’s procedures to ensure any errors are caught in a timely manner. Individual Responsible – Caleb Loss, Vice President for Business and Finance Anticipated Completion Date – April 2025

View Audit 351214

Finding 544690 (2024-004)

Significant Deficiency 2024

Tusculum University

TN

Subrecipient Monitoring Student Financial Aid Significant Deficiency

2024-004 Significant Deficiency: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) (Repeat Finding: 2023-002) Name of Contact Person Casey Reagan, Registrar, and Chris Summey, Head of our IT Department, are the designated employees in cha...

2024-004 Significant Deficiency: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) (Repeat Finding: 2023-002) Name of Contact Person Casey Reagan, Registrar, and Chris Summey, Head of our IT Department, are the designated employees in charge of overseeing the GLBA Policy Corrective Action Planned During the audit, it was noted that the University’s Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University during the 2024 year. A new policy was put into place during June 2024. During the 2023-24 academic year, the policy was being updated to be compliant. Due to this finding in 2022-23, the FSA Cyber Compliance Team reached out to Tusculum and Tusculum provided the Corrective Action Plan and new policy. On August 1st, 2024, Tusculum received word that the CAP acceptably addressed the GLBA finding. Anticipated Completion Date 08/1/2024

View Audit 351195

Finding 544689 (2024-005)

Significant Deficiency 2024

Tusculum University

TN

Student Financial Aid Reporting Significant Deficiency

2024-005 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001 and 2023-003) Name of Contact Person Casey Reagan, Registrar, an...

2024-005 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001 and 2023-003) Name of Contact Person Casey Reagan, Registrar, and Melissa White, Director of Financial Aid, are responsible for enrollment reporting. Casey Regan for the data and Melissa White for uploading the report to clearinghouse. Corrective Action Planned During the audit, it was noted that Due to lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. While the university did implement changes from the prior year, including randomly sampling students, after this finding and looking into the issue that was occurring, we found three more issues with our clearinghouse data. The first issue was our graduation file that was sent to clearinghouse was not being processed and being rejected. We were unaware of the rejection of the records. We have worked with a clearinghouse representative and created a new way of pulling the graduate students report to ensure that their status is properly reported and sent to NSLDS. The second issue was that some student files were individually being rejected and thus not processing fully through. To correct this issue, we are watching the rejected clearinghouse files for individual students and are manually reporting their statuses if we cannot get the file to accept. The final and third issue was that students who were unofficially or administratively withdrawn were pulling the wrong date and thus the status was showing the wrong dates for the occurrence. To fix this, financial aid and the registrar are working in tandem to ensure that the correct date that the actual unofficial withdrawal or administrative withdrawal is correct. If necessary, we will manually certify these students as well. Anticipated Completion Date 03/01/2025

View Audit 351195

Finding 544688 (2024-003)

Significant Deficiency 2024

Tusculum University

TN

Student Financial Aid Reporting Significant Deficiency

2024-003 Significant Deficiency: Federal Work-Study (FWS) (U.S. Department of Education, Federal Work-Study Program, ALN #84.033) Name of Contact Person Melissa White, Director of Financial Aid, is responsible for ensuring that Federal Work Study students are not working during class time. Correct...

2024-003 Significant Deficiency: Federal Work-Study (FWS) (U.S. Department of Education, Federal Work-Study Program, ALN #84.033) Name of Contact Person Melissa White, Director of Financial Aid, is responsible for ensuring that Federal Work Study students are not working during class time. Corrective Action Planned During the audit, it was noted that Tusculum failed to compare hours submitted as worked hours to student class schedules. In order to ensure that this does not occur again, all supervisors have been reminded of the requirement that students do not work during seat time. Regular reminders sent to supervisors and regular trainings are offered to supervisors to remind supervisors of the Federal Work Study Guidelines. In addition, as each timesheet is submitted, financial aid shall check to ensure no violations have occurred. Anticipated Completion Date 10/15/2024

View Audit 351195

Finding 544687 (2024-002)

Significant Deficiency 2024

Tusculum University

TN

Student Financial Aid Reporting Significant Deficiency

2024-002 Significant Deficiency: Federal Work-Study (FWS) Underpayment (U.S. Department of Education, Federal Work-Study Program, ALN #84.033) Name of Contact Person Melissa White, Director of Financial Aid, is responsible for ensuring that Federal Work Study students are properly paid for hours w...

2024-002 Significant Deficiency: Federal Work-Study (FWS) Underpayment (U.S. Department of Education, Federal Work-Study Program, ALN #84.033) Name of Contact Person Melissa White, Director of Financial Aid, is responsible for ensuring that Federal Work Study students are properly paid for hours worked. Corrective Action Planned During the audit, it was noted that Tusculum errantly miscalculated hours worked and wages payable results in student receiving fewer Title IV funds than what they may have earned or be eligible for. Once found, the missing hours were added to the next payroll and the students were paid. To ensure this error does not occur again in the future, financial aid has created a secondary check system that includes keeping an additional excel that confirms that each timesheet has been paid for each student and that their full hours worked have been paid. We have also reinforced with supervisors the urgency of making sure timesheets are submitted in a timely manner so that the error does not occur again as the timesheets in question were late timesheets. Additional training for supervisors and constant reminders to supervisors are also ongoing. Anticipated Completion Date 10/15/2024

View Audit 351195

Finding 544631 (2024-001)

Significant Deficiency 2024

Trustees of the College of the Holy Cross

MA

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

Corrective Action Plan: The identified conditions relate to students who graduated off-cycle. To mitigate the risk of future status change reporting issues, the College is implementing an additional monthly review process that will generate a report of students who have separated from the College. T...

Corrective Action Plan: The identified conditions relate to students who graduated off-cycle. To mitigate the risk of future status change reporting issues, the College is implementing an additional monthly review process that will generate a report of students who have separated from the College. This report will be reconciled with student status changes transmitted by the National Student Clearinghouse (NSC) to the National Student Loan Database System (NSLDS), and any necessary corrections will be made immediately. Timeline for Implementation of Corrective Action Plan: These corrective actions are being implemented in Spring 2025.

View Audit 351172

Finding 544518 (2024-003)

Significant Deficiency 2024

Allen University

NC

Questioned Costs Student Financial Aid Procurement, Suspension & Debarment

Finding 2024-003 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiencies): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. 1) The College...

Finding 2024-003 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiencies): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. 1) The College did not reconcile the following programs between the Office of Financial Aid and the Business Office. Per 34 CFR 685.300(b)(5). a. Federal Pell Grant Program b. Federal Direct Student Loans c. Federal SEOG d. Federal Work-Study (FWS) Program 2) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations Report and Application to Participate (FISAP) for the programs below: a. Federal Pell Grant Program b. Federal Work-Study (FWS) Program c. Federal SEOG 3) Thirty-two out of 60 students had a credit balance on their account created by Title IV program funds longer than 14 days. 34 CFR 668.164(h)(1). Auditor's Recommendation – The University should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. Corrective Action – Refunds – The refund non-compliance is contributed to the institution’s ERP (Jenzabar) not being operational for about 7 months. This hindered the staff’s ability to properly review and process student refunds timely. The institution has a process in place to ensure compliance of distribution and is also enhancing the student refund module to improve timeliness of refund distribution. Federal Reconciliations and FISAP – The non-compliance is contributed to the institution’s ERP (Jenzabar) not being operational for about 7 months. This hindered the staff’s ability to properly reconcile federal funds timely and assurance in accuracy in completing the FISAP. In addition, the software enhancements for the Accounting modules, the institution has purchased a system enhancement for Financial Aid to be able to centralize FA processing and generate Federal Reconciliations and FISAP report. The Jenzabar Financial Aid software will assist the institution with maintaining compliance with all external federal reporting.

View Audit 351159 Questioned Costs: $1

Finding 544471 (2024-001)

Significant Deficiency 2024

American International College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action Plan: In March of 2024, the College created a policy that implemented scheduled disbursement dates to ensure the timely recording of disbursement dates. The finding for June 30, 2024, single audit occurred before the new policy was in effect. The number of findings also decreased...

Corrective Action Plan: In March of 2024, the College created a policy that implemented scheduled disbursement dates to ensure the timely recording of disbursement dates. The finding for June 30, 2024, single audit occurred before the new policy was in effect. The number of findings also decreased, and students audited after the corrective action was put into place were done correctly. To continue to mitigate this from occurring in the future, the College has implemented a report that will show differences in the date Direct Student Loan funds are disbursed in Powerfaids versus the date the funds are applied to a student’s ledger, and date shown as disbursed in COD. All differences will be investigated and rectified on a biweekly basis. Timeline for Implementation of Corrective Action Plan: Implemented in March 2024 Contact Person Lynn Comtois Director of Financial Aid

View Audit 351150

Finding 544397 (2024-001)

Significant Deficiency 2024

Michigan State University

MI

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility

Condition: The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Planned Corrective Action: Missing notifications to students was a result of a coding error in the automated process that was resolved on S...

Condition: The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Planned Corrective Action: Missing notifications to students was a result of a coding error in the automated process that was resolved on September 5, 2023. Notifications to parents didn’t begin until the Summer 2023, with an automated procedure being implemented in the Fall 2023 semester. A coding issue was identified and resolved in the automated procedure to notify parents in early January 2024. Contact person responsible for corrective action: Kent McGowan, Assistant Director, Office of Financial Aid Anticipated Completion Date: This finding was corrected as of January 2024.

View Audit 351055

Finding 544337 (2024-001)

Material Weakness 2024

Dominican University

IL

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring

Reporting – The University will review and update current procedures to ensure timely processing and monitoring of NSLDS reports. Internal reports will be run simultaneously to make sure all students are captured and their status is correctly reported. Anticipated Completion Date - September 30, ...

Reporting – The University will review and update current procedures to ensure timely processing and monitoring of NSLDS reports. Internal reports will be run simultaneously to make sure all students are captured and their status is correctly reported. Anticipated Completion Date - September 30, 2024; Responsible Contact Person for Planned Corrective Action - Tina Baskin, Executive Director of Financial Aid & Enrollment Services

View Audit 350931

Finding 544176 (2024-005)

Significant Deficiency 2024

Delaware State University

DE

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

2024-005 Student Financial Assistance Cluster – CFDA Nos. 84.063, 84.033 and 84.268 – Credit Balances Recommendation: We recommend that the University reevaluate its process to ensure that credit balances on student accounts due to the application of title IV funds are refunded within 14 days. Expla...

2024-005 Student Financial Assistance Cluster – CFDA Nos. 84.063, 84.033 and 84.268 – Credit Balances Recommendation: We recommend that the University reevaluate its process to ensure that credit balances on student accounts due to the application of title IV funds are refunded within 14 days. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: ERP (Banner) system was being used to generate reporting for credit balances. A glitch was discovered using this process due to application of payment. Student Accounts change the reporting method to Argos, which provided a more accurate and timely report of all credit balances regardless of the disbursement term. Name(s) of the contact person(s) responsible for corrective action: AVP of Student Accounts, Carold Boyer-Yancy & Senior Associate Director of Operations, Lindsay Sands Planned completion date for corrective action plan: December 2024

View Audit 350927

Finding 544175 (2024-004)

Significant Deficiency 2024

Delaware State University

DE

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2024-004 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, and 84.268 – Outstanding Refund Checks Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior...

2024-004 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, and 84.268 – Outstanding Refund Checks Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior to the 240-day deadline. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: The Assistant Controller will implement review procedures for timely reconciliation of bank and ledger accounts & maintain an accurate listing of those discrepancies. This information will be timely shared with respective teams to address. Name(s) of the contact person(s) responsible for corrective action: Assistant Controller, Clifton Smith, II. Planned completion date for corrective action plan: July 2025

View Audit 350927

Finding 544174 (2024-003)

Material Weakness 2024

Delaware State University

DE

Matching / Level of Effort / Earmarking Student Financial Aid Material Weakness § 200.303

2024-003 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally...

2024-003 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the 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 taken in response to finding: The Registrar’s Office will review and strengthen the enrollment report to ensure it pulls all required information according to the needs of the National Student Clearinghouse (NSCL) and the National Student Loan Data System (NSLDS). The Registrar’s Office will continue to work with the National Student Clearinghouse (NSCL) and National Student Loan Data System (NSLDS) on the specific enrollment submission scenarios that require a different submission/update requirement. Name(s) of the contact person(s) responsible for corrective action: University Registrar, Dr. Genita Mangum Planned completion date for corrective action plan: December 2025

View Audit 350927

Finding 544159 (2024-007)

Significant Deficiency 2024

Washington Adventist University

MD

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

Action taken in response to finding: A formal review of will take place of NSLDS reporting. Written policy with a monthly checklist will be developed to be in compliance with the regulation for student statuses. Name(s) of the contact person(s) responsible for corrective action: Patrick Farley Plan...

Action taken in response to finding: A formal review of will take place of NSLDS reporting. Written policy with a monthly checklist will be developed to be in compliance with the regulation for student statuses. Name(s) of the contact person(s) responsible for corrective action: Patrick Farley Planned completion date for corrective action plan: June 30, 2025

View Audit 350924

Finding 544141 (2024-006)

Significant Deficiency 2024

Washington Adventist University

MD

Subrecipient Monitoring Student Financial Aid

Action taken in response to finding: To address the identified deficiencies in WAU’s written information security program and ensure compliance with 16 CFR § 314.4, the following actions have been taken: 1. Approval of the Information Security Program: o Action: We have updated the written informat...

Action taken in response to finding: To address the identified deficiencies in WAU’s written information security program and ensure compliance with 16 CFR § 314.4, the following actions have been taken: 1. Approval of the Information Security Program: o Action: We have updated the written information security program as formally approved by the appropriate individual within the institution, Rosalee Pedapudi, ITS Director. This step designates a qualified individual responsible for overseeing and implementing the information security program as a requirement under 16 CFR § 314.4(a). 2. Design and Implementation of Safeguards: o Action: According to 16 CFR § 314.4(c), institutions must implement safeguards to control identified risks, including encryption of customer information in transit and at rest. We have documented specific safeguards to control the risks identified through the institution's risk assessment, including a policy mandating the encryption of customer information both on the institution's systems and during transmission. As such, the university encrypts Non-Public Financial information both at rest and in transit using industry-standard encryption protocols (e.g. VPN). Where encryption is not feasible, compensating controls are implemented to protect sensitive data. The university also requires Multifactor Authentication (MFA) for systems that process, store, or transmit protected financial information. Access is governed by the principle of least privilege, with privileged access granted by authorized university officers, ensuring that only approved personnel can access sensitive data. 3. Regular Testing and Monitoring of Safeguards: o Action: According to 16 CFR § 314.4(d), WAU is required to regularly test and monitor the effectiveness of their safeguards to ensure the security of customer information. We have established procedures for annual penetration testing through Applied Technology Services and monitoring of the effectiveness of the implemented safeguards. Name(s) of the contact person(s) responsible for corrective action: Rosalee Pedapudi Planned completion date for corrective action plan: July 15, 2025.

View Audit 350924

Finding 544139 (2024-003)

Significant Deficiency 2024

Washington Adventist University

MD

Questioned Costs Eligibility Student Financial Aid § 200.303

Action taken in response to finding: The University has SAP policies and procedures in place to determine student’s eligibility for Financial Aid that complies with Federal regulations, including qualitative (GPA), quantitative (pace of completion) and maximum timeframe standards. The SAP finding m...

Action taken in response to finding: The University has SAP policies and procedures in place to determine student’s eligibility for Financial Aid that complies with Federal regulations, including qualitative (GPA), quantitative (pace of completion) and maximum timeframe standards. The SAP finding may be due to system error with the Colleague ERP when the SAP report was run. The University will evaluate our SAP procedures and perform internal audits to identify gaps or inconsistencies and implement corrective actions as needed. Training will be provided to financial aid staff on SAP requirements and procedures to ensure consistent application and understanding. Name(s) of the contact person(s) responsible for corrective action: Alfred Taylor Planned completion date for corrective action plan: June 30, 2025

View Audit 350924 Questioned Costs: $1

Finding 544138 (2024-002)

Material Weakness 2024

Washington Adventist University

MD

Student Financial Aid Internal Control / Segregation of Duties Cash Management § 200.303

Action taken in response to finding: Washington Adventist University (WAU) is evaluating its current internal control and will make the necessary improvements so as to assure accuracy and compliance with the laws and regulations applicable to WAU. Furthermore, WAU will map internal control to impro...

Action taken in response to finding: Washington Adventist University (WAU) is evaluating its current internal control and will make the necessary improvements so as to assure accuracy and compliance with the laws and regulations applicable to WAU. Furthermore, WAU will map internal control to improve segregation of duties where possible and follow the Committee of Sponsoring Organizations of the Treadway Commission best practices for small business. Name(s) of the contact person(s) responsible for corrective action: Alfred Taylor Planned completion date for corrective action plan: June 30, 2025.

View Audit 350924

Finding 544136 (2024-001)

None 2024

Trinity Christian College

IL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

All graduate and withdrawn student files will be reviewed on a monthly basis to verify any status changes are reported to NSLDS within regulatory timeframes. Training and professional development will be required for responsible staff to ensure a compliance schedule is developed. Personnel will be e...

All graduate and withdrawn student files will be reviewed on a monthly basis to verify any status changes are reported to NSLDS within regulatory timeframes. Training and professional development will be required for responsible staff to ensure a compliance schedule is developed. Personnel will be evaluated to ensure existing policies, procedures, and processes are followed and supported through corrective action where needed.

View Audit 350923

Finding 544094 (2024-001)

Significant Deficiency 2024

Quinnipiac University

CT

Student Financial Aid Procurement, Suspension & Debarment Cash Management

Uniform Guidance Corrective Action Plan Year ended June 30, 2024 Federal Finding #2024-001 Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education as soon as possible, bu...

Uniform Guidance Corrective Action Plan Year ended June 30, 2024 Federal Finding #2024-001 Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines the student withdrew. Quinnipiac University agrees with the finding. For one student who withdrew during the 2023 – 2024 academic year, the Direct Loan funds awarded to that student were not returned to the student financial assistance account within 45 days after the University determined the student withdrew. For one student who withdrew during the 2023 – 2024 academic year, the Pell and Direct Loan funds awarded to that student were not returned to the student financial assistance account within 45 days after the University determined the student withdrew. The finding is attributed to programs previously being reconciled monthly or when enough authorized funds became available within G5. At the time the above students withdrew, there were not enough authorized funds to process the net total of draw downs and returns so a batch was held until more funds were available, which resulted in returns surpassing the 45 day threshold. In December 2023, Management implemented additional steps within the reconciliation process of Title IV awards in order to prioritize the return of any unearned Title IV awards so that they are remitted to the student financial assistance account within G5 in a timely manner. The students mentioned above withdrew prior to these additional steps being implemented. If the Office of Management and Budget have questions regarding this plan, please reach out to Stephen Allegretto, the Associate Vice President for Finance and Controller, who is responsible for ensuring this corrective action plan is implemented, at 203-582-7962.

View Audit 350901

Finding 544090 (2024-006)

Significant Deficiency 2024

Jersey City Public Schools

NJ

Student Financial Aid Reporting

The District's budget report related to the ESEA Title IV program be reviewed to ensure that appropriations and resulting balances accurately reflect remaining program funds available.

View Audit 350893

Finding 544082 (2024-001)

Significant Deficiency 2024

Bridgewater College

VA

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

2024-001 Enrollment Reporting (Significant Deficiency), Department of Education, Student Financial Aid Cluster, Special Tests and Provisions Condition: The College did not report student enrollment data to the National Student Clearinghouse within the minimum required timeframe. Criteria: Unless it ...

2024-001 Enrollment Reporting (Significant Deficiency), Department of Education, Student Financial Aid Cluster, Special Tests and Provisions Condition: The College did not report student enrollment data to the National Student Clearinghouse within the minimum required timeframe. Criteria: Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended (34 CFR 685.309(b)(2)(i)). Cause: The College does not have adequate procedures in place to ensure students’ enrollment statuses are updated on NSLDS timely. Effect: Enrollment data was not reported timely or accurately to the Department of Education thus, the Department could not properly service the students’ loans. The accuracy of the Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. Context: From a population of 42 students that withdrew officially during a term, we tested 5 students and noted that all 5 were not reported timely. Recommendation: We recommend that the College put procedures in place to ensure that any changes in student enrollments are properly tracked and updated to the NSLDS. Management Response: When the Registrar’s Office is notified of a student’s withdrawal (official or unofficial), within 24 hours the student’s record in the National Student Clearinghouse will be manually flagged as withdrawn with their last date of attendance. Party responsible: Sherry A. Phelps Office phone: 540-828-5313 Email address: sphelps2@bridgewater.edu Expected date of correction: This problem was corrected on 6/27/2024 when it was brought to my attention and since that date the required information has been correctly reported directly into the National Student Clearinghouse within 24 hours of the date of determination of a student’s withdraw from the college.

View Audit 350883

Finding 542030 (2024-002)

Significant Deficiency 2024

University of Pikeville

KY

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

Federal Program: U.S. Department of Education Federal Direct Loan Program, Federal Assistance Listing 84.268 Criteria: The University is required to comply with 36 CFR Section 685.309(b). Condition: During our testing of 40 students for eligibility, we noted three students in which the students' ...

Federal Program: U.S. Department of Education Federal Direct Loan Program, Federal Assistance Listing 84.268 Criteria: The University is required to comply with 36 CFR Section 685.309(b). Condition: During our testing of 40 students for eligibility, we noted three students in which the students' status change was not timely reported to the National Student Loan Database System (NSLDS). Corrective Actions Taken or Planned: For the year ended June 30, 2024, three students were reported late to NSLDS. Each student, after being identified, were then reported to NSLDS with the correct status and date. The Office of Institutional Research will work with the Registrar’s Office to ensure that students are reported in a timely manner. The Director of Institutional Research has provided the following steps that will be taken when a student is reported as withdrawn: 1. View the student's transcript in Ellucian to see if he/she withdrew or is back-dated as never enrolling. 2. Update Excel file for the term enrollment accordingly. 3. Update National Student Clearinghouse (NSC) file that will be submitted on the next due date. 4. Manually update the student's enrollment in National Student Clearinghouse 5. Manually update the student's enrollment in NSLDS Name of Responsible Person: Daniel Donner, Director of Financial Aid Completion Date: August 13, 2024

View Audit 350857

Finding 542029 (2024-001)

Significant Deficiency 2024

University of Pikeville

KY

Questioned Costs Student Financial Aid Eligibility

Finding 2024-001 Federal Program: U.S. Department of Education Federal Pell Grant Program, Federal Assistance Listing 84.063 Criteria: The University must comply with 34 CFR 690.61(a)(1). Condition: During our testing of 40 students for eligibility, we noted one student who was eligible for a Pel...

Finding 2024-001 Federal Program: U.S. Department of Education Federal Pell Grant Program, Federal Assistance Listing 84.063 Criteria: The University must comply with 34 CFR 690.61(a)(1). Condition: During our testing of 40 students for eligibility, we noted one student who was eligible for a Pell grant, but was not awarded nor disbursed a Pell grant. Upon further analysis, there were four additional students that were eligible for a Pell grant and were not awarded nor disbursed a Pell grant. Corrective Actions Taken or Planned: For the year ended June 30, 2024, it was found that some students were not awarded eligible Pell grants. After the initial students were discovered, the University reviewed all students that were active for the 2023-2024 award year and reviewed their most current Institutional Student Information Record (ISIR) to determine which students may not have been awarded Pell grants correctly. Affected students were then awarded as needed and funds applied to their account. Going forward, the University will review subsequent student ISIRs and run additional reports to ensure students are awarded the correct amount of Pell grants. This additional review will capture those who would have previously been missed. Name of Responsible Person: Daniel Donner, Director of Financial Aid Completion Date: August 13, 2024

View Audit 350857 Questioned Costs: $1

Finding 541990 (2024-004)

Significant Deficiency 2024

College Unbound

RI

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2024 Corrective Action Plan: Previously, this was an ancillary work task for a staff member in a different department. CU has since hired an experienced Registrar and ...

Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2024 Corrective Action Plan: Previously, this was an ancillary work task for a staff member in a different department. CU has since hired an experienced Registrar and begun training an Associate Registrar. The dedicated department now updates Clearinghouse on the required monthly basis. All previous records have been corrected. Timeline for Implementation of Corrective Action Plan: Completed Contact Person: Mark Hartonchik, CFO

View Audit 350797

Corrective Action Plans

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