Corrective Action Plans

Finding 1169503 (2025-004)

Material Weakness 2025

AL

Student Financial Aid Special Tests & Provisions Reporting

Finding 2025 – 004 - Special Tests and Provisions- Enrollment Reporting (Significant Deficiency and Noncompliance) Management’s Response: Management concurs with the above finding, and the Fiscal Service Office will implement corrective action before September 2026. Management acknowledges the proce...

Finding 2025 – 004 - Special Tests and Provisions- Enrollment Reporting (Significant Deficiency and Noncompliance) Management’s Response: Management concurs with the above finding, and the Fiscal Service Office will implement corrective action before September 2026. Management acknowledges the process gap as indicated and noted in the above findings. The Director of Admissions and Records has stated that students who have a student attribute in Banner of INTL will no longer be excluded from the National Student Clearinghouse enrollment reporting upload so as to prevent any reporting issues due to human error when processing admissions applications.

View Audit 382425

Finding 1169432 (2025-001)

Material Weakness 2025

Concordia University, Inc. and Affiliate

WI

Student Financial Aid Eligibility

2025-001: Missing Exit Counseling Documentation Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, 84.379 Grant Period – Year Ended June 30, 2025 Condition Found Condition/Context: During our student file testing, we noted two students out of forty did not have d...

2025-001: Missing Exit Counseling Documentation Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, 84.379 Grant Period – Year Ended June 30, 2025 Condition Found Condition/Context: During our student file testing, we noted two students out of forty did not have documentation in their file that exit counseling was sent thirty days after the student withdrew. We consider the missing exit counseling to be an instance of noncompliance with the Eligibility Compliance Requirement. Corrective Action Plan Concordia has created new reporting and updated its Exit Counseling policy to put any students without concurrent semester enrollment, excluding traditional undergraduates who are not required to take summer, into "EXIT". Responsible person for corrective action plan: Kevin Sheridan Implementation Date of Corrective Action Plan: December 11, 2025

View Audit 382375

Finding 1169430 (2025-002)

Material Weakness 2025

University of the Cumberlands, Inc.

KY

Student Financial Aid Reporting Significant Deficiency

2025-002 Significant Deficiency: Working During Scheduled Class Time (U.S. Department of Education - Federal Work Study Program, ALN #84.033) The University noted that multiple students appear to have been paid for Federal Work Study hours logged and submitted for time the student was scheduled to b...

2025-002 Significant Deficiency: Working During Scheduled Class Time (U.S. Department of Education - Federal Work Study Program, ALN #84.033) The University noted that multiple students appear to have been paid for Federal Work Study hours logged and submitted for time the student was scheduled to be in class without verification of a reasonable exemption. Management Response Management concurs with the auditor’s finding. Due to incomplete documentation of reasonable exemptions, students were paid Federal Work Study funds for time worked during regularly scheduled class meeting times. Responsible Person(s) Alex Campbell, Director of Financial Aid, and Bobbi Farris, Manager for Student Employment, are the responsible parties for the corrective action. Corrective Action Plan Upon identifying deficiencies related to the lack of documentation for allowable exemptions, the University immediately communicated with all Student Employment Supervisors regarding permitted exemptions and required documentation for students to work during scheduled class times. These requirements and exemptions are reviewed and agreed upon during the annual Student Employment Supervisor Trainings, which occur prior to job postings. Students are notified of the documentation required to be exempt and eligible to work during a scheduled class time during the onboarding process. In collaboration with Information Technology and third-party consultants, the Student Employment Office is enhancing reporting functions to ensure accurate identification of students with conflicting work and class times and to flag any conflicting entries for review and resolution prior to approval. These reports will be reviewed each pay period to ensure accurate documentation is obtained for any conflicting times flagged. While these fields are being implemented, regulations related to working during scheduled class times have been reinforced with both students and supervisors. Beginning with the Spring 2026 term, the University will implement a new policy prohibiting students participating in the Federal Work Study Program from working during scheduled class times, regardless of any met exemptions. All Student Employment Supervisors will be notified of this updated policy by the end of the Fall 2025 term. Training will continue on an annual basis to ensure proper procedures are followed by Student Employment Supervisors and students participating in the Federal Work Study Program. The Director of Financial Aid and Manager for Student Employment will review student time records each pay period to ensure full compliance with these policies. Expected Completion Date This corrective action plan was implemented in September 2025, during the Fall 2025 term. Final implementation will occur at the start of the Spring 2026 term.

View Audit 382359

Finding 1169429 (2025-001)

Material Weakness 2025

University of the Cumberlands, Inc.

KY

Student Financial Aid Eligibility Reporting

2025-001 Significant Deficiency: Awards in Excess of Aggregate Limits (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) The University awarded and disbursed Federal Direct Loans beyond aggregate limits. Management Response Management concurs with the auditors’ finding....

2025-001 Significant Deficiency: Awards in Excess of Aggregate Limits (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) The University awarded and disbursed Federal Direct Loans beyond aggregate limits. Management Response Management concurs with the auditors’ finding. Due to delays and changes in the National Student Loan Data System (NSLDS) post-screening process for the 2024–25 award year, Federal Direct Loans were inadvertently awarded and disbursed to students who had previously exceeded Federal Direct Loan aggregate limits. Responsible Person(s) Alex Campbell, Director of Financial Aid, and Kaitrin Parrett, Assistant Director of Financial Aid, are designated as the individuals responsible for implementing the corrective action. Corrective Action Plan Upon identifying deficiencies in loan aggregate reporting and over-award status, the Financial Aid Office initiated communication with the identified students to inform them of their overaward status and the process for resolving inadvertent overborrowing. In collaboration with software engineers, the Financial Aid Office is developing updated reporting to ensure proper identification of students who are ineligible due to meeting or exceeding aggregate limits set by the U.S. Department of Education. The Financial Aid Office tested and reviewed NSLDS post-screen data and student loan aggregates prior to the disbursement of Fall 2025 Federal Direct Loans to ensure students were not awarded or disbursed aid for which they were ineligible. Reviews of NSLDS post-screen data confirm that the Student Information System (SIS) accurately identifies student aggregate borrowing flags. The Financial Aid Office is also monitoring designated mailboxes to ensure any additional NSLDS post-screen data is reviewed and aggregate limits on student accounts are updated accordingly. All financial aid staff involved in awarding federal loans completed additional training on NSLDS review requirements, aggregate limit monitoring, and reaffirmation procedures prior to Fall 2025 disbursements. Training will continue on a quarterly basis to ensure proper procedures are followed by Financial Aid staff. Compliance reviews will be conducted on a semester basis to ensure that Title IV aid is not awarded to students in excess of their annual or aggregate limits. The Director and Assistant Director of Financial Aid will review aggregate limit reports monthly as part of the University’s internal operational calendar. Expected Completion Date This corrective action plan was implemented in September 2025, prior to Fall 2025 aid disbursements, which began on September 12, 2025.

View Audit 382359

Finding 1169412 (2025-003)

Material Weakness 2025

Life University, Inc.

GA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Individuals Responsible for Corrective Action Plan: •Collections Coordinator •Director of Student Accounts Condition: Life University transitioned from UAS services to ECSI. In the transition of that service provides, documentation that was to be maintained to remain compliant with the Federal Perki...

Individuals Responsible for Corrective Action Plan: •Collections Coordinator •Director of Student Accounts Condition: Life University transitioned from UAS services to ECSI. In the transition of that service provides, documentation that was to be maintained to remain compliant with the Federal Perkins loan program was lost. The university has attempted on numerous occasions to assign the defaulted loans using alternative documentation to verify the debt. All attempts have been denied. The university has now been in practice with the current corrective action plan to address the deficiencies in documentation and reestablish the validity of the debt. Management’s Corrective Action Plan: Life University has implemented and continues to maintain the following corrective measures to ensure ongoing compliance: 1.Borrower Contact and Notification Life University has initiated and continues to conduct proactive outreach to borrowersrequiring an updated or newly established MPN (Master Promissory Note) or equivalentdocumentation. Communication is conducted through multiple channels, including: •Phone •Email 2.Clear Documentation Instructions The University will continue to issue formal notices to affected borrowers outlining therequirement for a new MPN or equivalent documentation. Each notice includes step-by-stepinstructions for completion, a clear explanation of the purpose and importance of the MPN,and information regarding its impact on the borrower’s outstanding loan balance. 3.Reassignment of Collection Rights Upon borrower completion of the required documentation, Life University has coordinatedwith ECSI to reassign the University’s right to collect on any remaining balances. This processcontinues to be applied as additional borrowers complete their documentation. 4.Documentation Review and Verification The University has established and continues to follow a review process to verify that eachnew MPN is complete, accurate, and properly executed. This ensures that borrower consentis valid and that all collection rights are appropriately reassigned. 5.Financial Record Updates Life University has updated and continues to maintain accurate financial records reflectingthe new MPNs and reassigned collection rights. Outstanding amounts, repayment schedules,and related data are verified and recorded to ensure consistency with federal andinstitutional requirements. 6.Ongoing Communication and Monitoring The University continues to monitor borrower compliance and maintain communicationthroughout the process. Regular follow-ups and reminders are sent as needed to ensuretimely completion and documentation integrity. At the conclusion of a 12 month outreach,students who have not verified their debt to come within compliance will be written off. Anticipated Completion Date: ongoing

View Audit 382340

Finding 1169411 (2025-002)

Material Weakness 2025

Life University, Inc.

GA

Student Financial Aid Special Tests & Provisions

Individuals Responsible for Corrective Action Plan: •Director of Student Accounts •IT Systems Administrator •CIO •Senior Director of Student Administration and Compliance Cause: The notification for this student was not generated due to timing and process gaps associated with the data security incid...

Individuals Responsible for Corrective Action Plan: •Director of Student Accounts •IT Systems Administrator •CIO •Senior Director of Student Administration and Compliance Cause: The notification for this student was not generated due to timing and process gaps associated with the data security incident that occurred on July 30, 2024. The disbursement posted on Thursday, July 25, one day after the automated report selection window closed. As the team worked to assess the impact of the security incident, this process was not reviewed and this record fell outside of the reporting cycle and was not manually identified for notification. Management’s Corrective Action Plan: Incident Response and Process Impact Assessment: •Develop a standard protocol for identifying and reviewing business processes that may beimpacted during or after a data security event. •Document any suspended or delayed processes during an incident and report to IT andfollow-up. •Conduct a post-incident reconciliation of all financial aid transactions (disbursements,notifications, adjustments) to ensure completeness and compliance. •Collaborate with IT to include critical Student Account processes in the business continuityand recovery plan, ensuring prioritized restoration after any system outage or data event. Anticipated Completion Date: 2/9/2026

View Audit 382340

Finding 1169410 (2025-001)

Material Weakness 2025

Life University, Inc.

GA

Student Financial Aid Special Tests & Provisions

Individuals Responsible for Corrective Action Plan: •Dr. Lee Skinkle, VPAA •Elizbeth Geisz, Registrar •Melissa Waters, Senior Director Student Administration and Compliance Condition: The University did not report students’ status changes accurately and within the required timeframe. Management’s Co...

Individuals Responsible for Corrective Action Plan: •Dr. Lee Skinkle, VPAA •Elizbeth Geisz, Registrar •Melissa Waters, Senior Director Student Administration and Compliance Condition: The University did not report students’ status changes accurately and within the required timeframe. Management’s Corrective Action Plan: 1.Improved Identification of Withdrawals Per the University’s attendance policy, the Academics team promptly reviews students who haveceased academic activity for 14 consecutive days. Students meeting this criterion are identified androuted to the Registrar’s Office for processing as unofficial withdrawals within the required federaltimeframe. This procedure ensures timely and accurate reporting of enrollment status changes andeliminates the need to backdate information in the SIS, NSC, and NSLDS. 2.Refined Enrollment and Registration Deadlines Enrollment and registration deadlines have been tightened and communicated across alldepartments. Reducing late registration activity minimizes backdated actions that can result ininaccurate program-level and campus-level effective dates in NSC and NSLDS reporting. 3.Review and Adjustment of the Dismissal Timeline The dismissal process timeline is being reviewed and updated to ensure students have sufficienttime to meet enrollment and registration deadlines for subsequent academic periods. This reduceslate or retroactive enrollment-status changes that affect NSLDS timeliness. 4.Enhanced Quality Assurance for Enrollment Reporting Monthly quality checks will be performed on reports related to withdrawals, graduations, programchanges, and registration activity prior to submission to the NSC. These checks will specificallyverify: •Accuracy of program begin dates and program enrollment effective dates, •Accuracy and timeliness of campus-level enrollment status changes, and •Compliance with the 30-day/60-day federal reporting requirement. 5.Monitoring of NSC Transmission and NSLDS Reporting Timelines The University will monitor NSC transmission cycles and verify that all required enrollment changesare submitted in time to meet federal requirements under 34 CFR 685.309. 6.Updated Procedures and Staff Training Revised procedures outlining updated deadlines, reporting expectations, and QC steps will bedocumented and shared with all Enrollment, Registrar, and Deans. Targeted training will beprovided to ensure consistent and accurate implementation of these requirements. Anticipated Completion Date: The University intends to institute these beginning of January of 2026.

View Audit 382340

Finding 1169370 (2025-001)

Material Weakness 2025

Community College District of Newton and McDonald Counties, Missouri

MO

Student Financial Aid Reporting Significant Deficiency

Corrective Action Plan December 19, 2025 U.S. DEPARTMENT OF EDUCATION Crowder College respectfully submits the following corrective action plan for the year ended June 30, 2025. Contact information for the individual responsible for the corrective action: Mr. Joseph Brenner, Vice President of Financ...

Corrective Action Plan December 19, 2025 U.S. DEPARTMENT OF EDUCATION Crowder College respectfully submits the following corrective action plan for the year ended June 30, 2025. Contact information for the individual responsible for the corrective action: Mr. Joseph Brenner, Vice President of Finance Crowder College 601 Laclede Avenue Neosho, MO 64850 (417) 451-3223 Independent public accounting firm: KPM CPAs, PC, 1445 E Republic Rd, Springfield, Missouri 65804 Audit Period: Year Ended June 30, 2025 The finding from the June 30, 2025, audit of the financial statements is below. The findings is numbered with the number assigned in the schedule. FINDING - MAJOR FEDERAL AWARD PROGRAM AUDIT 2025-001 Special Test and Provisions - Return of Title IV Funds Recommendation: We recommend the College implement procedures to strictly comply with the requirements of 34 CFR §668.22 as it relates to calculations of return of Title IV funds. Corrective Action Taken: The College reviewed all accounts affected by this error and identified 15 students whose accounts required adjustments. Upon review, the financial aid representative determined that excess funds were returned when the R2T4 calculations were completed. Financial Aid has since corrected the accounts and requested the additional funds owed. To prevent this issue from recurring, a representative from the Financial Aid Office will be included on the calendar committee. Additionally, Financial Aid Policies and Procedures have been updated to require calendar changes to be promptly updated in PowerFaids to ensure accuracy. Anticipated Completion Date: Fall semester 2025 and ongoing. Sincerely, Joseph Brenner Vice President of Finance

View Audit 382304

Finding 1169359 (2025-001)

Material Weakness 2025

Missouri Western State University

MO

Student Financial Aid

Missouri Western State University will meet the requirements in accordance with 34 CFR Section 685.309 by reviewing the enrollment reporting submitted to NSLDS through the National Student Clearinghouse (NSC) each month and comparing to Missouri Western State University’s student information system ...

Missouri Western State University will meet the requirements in accordance with 34 CFR Section 685.309 by reviewing the enrollment reporting submitted to NSLDS through the National Student Clearinghouse (NSC) each month and comparing to Missouri Western State University’s student information system to ensure that all dates and information submitted for the month is accurate and timely.

View Audit 382298

Finding 1169350 (2025-001)

Material Weakness 2025

Wayland Baptist University

TX

Student Financial Aid Material Weakness Reporting

Lack of Administrative Capability Planned Corrective Action: The Office of Financial Aid and Wayland Baptist University agree with this finding. To address the system limitations identified, the University has acquired a new Software-as-a-Service (SaaS) financial aid management system. This system w...

Lack of Administrative Capability Planned Corrective Action: The Office of Financial Aid and Wayland Baptist University agree with this finding. To address the system limitations identified, the University has acquired a new Software-as-a-Service (SaaS) financial aid management system. This system will replace the current platform and is intended to improve automation, reporting accuracy, workflow tracking, and overall compliance with federal and state financial aid requirements. In addition, the Office of Financial Aid is actively reevaluating workload distribution and staff assignments to ensure responsibilities are appropriately aligned with compliance-critical functions. The University is also increasing staffing levels within the Office of Financial Aid to strengthen oversight, reduce processing risk, and ensure timely and accurate completion of compliance and reporting obligations. Collectively, these actions are designed to enhance administrative capacity, strengthen internal controls, and mitigate the risk of future compliance deficiencies. Person Responsible for Corrective Action Plan: Executive Director of Financial Aid, Robert Hamilton, and Assistant Director of Compliance & Reporting, Brooke Tyler Anticipated Date of Completion: June 30, 2026

View Audit 382279

Finding 1169346 (2025-003)

Material Weakness 2025

Wayland Baptist University

TX

Student Financial Aid Material Weakness Reporting

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The Executive Director of Financial Aid and the Assistant Director of Compliance & Reporting will provide regular in-house R2T4 training specific to WBU for all financial aid staff. All financial aid staff responsible...

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The Executive Director of Financial Aid and the Assistant Director of Compliance & Reporting will provide regular in-house R2T4 training specific to WBU for all financial aid staff. All financial aid staff responsible for R2T4 will be required to complete pertinent training provided by FSA and purchased through NASFAA. In addition, financial aid staff responsible for R2T4 have established procedures to ensure the accurate and timely Return of Title IV Funds. To address the system limitations identified, the University has acquired a new Software-as-a-Service (SaaS) financial aid management system. Person Responsible for Corrective Action Plan: Executive Director of Financial Aid, Robert Hamilton, and Assistant Director of Compliance & Reporting, Brooke Tyler, and Assistant Director of Financial Aid, Alyssa Shealor Anticipated Date of Completion: June 30, 2026

View Audit 382279

Finding 1169345 (2025-002)

Material Weakness 2025

Wayland Baptist University

TX

Reporting Student Financial Aid Eligibility

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: WBU has entered into an agreement with Ellucian to implement Ellucian Student powered by Colleague as the new student information system. WBU will start utilizing this new student information syste...

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: WBU has entered into an agreement with Ellucian to implement Ellucian Student powered by Colleague as the new student information system. WBU will start utilizing this new student information system in April 2026. WBU will utilize the built-in functionality and tools to report to NSLDS at that time which should correct this issue completely. We will continue to work towards compliance with NSLDS reporting requirements through the following action plan: An internal SSRS report for official and unofficial withdrawals which accurately reflects withdrawn students remains available to the WBU offices of Financial Aid and the Registrar for verification as part of the planned corrective action. The custom NSC reporting tool(s) will continue to be updated to make sure the correct combination of fields and corresponding data sources are reported as accurately as possible. WBU will continue to work with NSC to mitigate issues related to data not transferring correctly between NSC and NSLDS. • A field-by-field analysis plus any needed corrections to the queries will be performed. o By default, term "W" withdrawals are reconsidered by the updated tool each time a report is generated for NSC. o Some date fields have been corrected that were previously misunderstood by the custom tool's historical authors. o Post-submission error corrections by registrar staff via NSC's website are spot-checked by Information Technology when requested. o If certain data issues cannot be resolved satisfactorily via NSC alone, then corrective measures via NSLDS directly may be considered. o The PowerCampus 9.1.2 baseline product's NSC reporting tool was determined to be insufficient for timely and accurate reporting to NSC with WBU's current data on several counts. WBU has upgraded the PowerCampus system to version 9.2.3 and will continue to work towards a solution for the baseline reporting tool with the upgraded system.  Some of the recurring data updates needed before running the PC baseline tool, are still being run periodically as a source data benefit for the custom tool. Person Responsible for Corrective Action Plan: Chief Information Officer, Cagan Cummings Anticipated Date of Completion: Ongoing

View Audit 382279

Finding 1169305 (2025-001)

Material Weakness 2025

Ave Maria School of Law and Ave Maria School of Law Foundation

FL

Student Financial Aid Special Tests & Provisions

2025-001 – Special Tests and Provisions - Enrollment Reporting Auditor Description of Condition and Effect. During our testing we noted that one student out of a testing population of twelve did not have their status change reported timely to NSLDS. As a result, there is an increased risk that infor...

2025-001 – Special Tests and Provisions - Enrollment Reporting Auditor Description of Condition and Effect. During our testing we noted that one student out of a testing population of twelve did not have their status change reported timely to NSLDS. As a result, there is an increased risk that information will not be reported to NSLDS on a timely basis. Auditor Recommendation. We recommend that the Organization enhance its policies and procedures regarding enrollment reporting to ensure that reporting is completed timely. Corrective Action. The institution concurs with the finding. The error resulted from a manual data entry into the withdrawn students' records. After consulting with our student information systems provider, we were informed about a Wizard that could accurately update the withdrawn date and prevent future reporting issues. The Registrar and IT have rectified the finding. They will implement a monthly review for withdrawn students to ensure the last day attended is reported accurately and on time. Responsible Person. Amy Howarth Anticipated Completion Date. 09 01 2025

View Audit 382247

Finding 1169302 (2025-001)

Material Weakness 2025

South Orange County Community College District

CA

Student Financial Aid Eligibility Significant Deficiency

Management's Response: We concur. Views of Responsible Officials and Corrective Action Plan Response: The two students identified were underpaid due to locks on their financial aid units for either late-start courses or being on an approved SAP appeal plan. Once locks were removed, PowerFAIDS should...

Management's Response: We concur. Views of Responsible Officials and Corrective Action Plan Response: The two students identified were underpaid due to locks on their financial aid units for either late-start courses or being on an approved SAP appeal plan. Once locks were removed, PowerFAIDS should have recalculated their aid to reflect their current units, however that did not happen. As a result, the Pell Grant was under-awarded. The students have now been disbursed with their full Pell eligibility. Corrective Action Plan: The transition from a legacy SIS and PowerFAIDS to a single ERP will consolidate financial aid and enrollment data into a single system, eliminating reliance on manual adjustments and reducing the risk of data discrepancies between two systems. Banner allows for automated and real-time recalculations for enrollment changes such as late start courses, reducing the risk of Pell under or over-awarding. Financial aid staff will receive updated training and guidance on the importance of verifying Pell recalculations when manual locks on student financial aid records are needed, for instance in the case of a student on an approved SAP appeal plan.

View Audit 382244

Finding 1169297 (2025-001)

Material Weakness 2025

University of Oklahoma Health Sciences Center

OK

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid

The following is the Recruitment and Admissions Corrective Action Plan for the single Audit Finding for FY25. Criteria or Specific Requirement: Special Tests and Provisions – NSLDS Reporting, 34 CFR Sections 690.83 (b)(2) and 685.309. Finding Summary: Student enrollment and program information was n...

The following is the Recruitment and Admissions Corrective Action Plan for the single Audit Finding for FY25. Criteria or Specific Requirement: Special Tests and Provisions – NSLDS Reporting, 34 CFR Sections 690.83 (b)(2) and 685.309. Finding Summary: Student enrollment and program information was not communicated to the National Student Loan Data System (NSLDS) timely or accurately. Officials Responsible for Ensuring Corrective Action: Shanna Pope, Registrar Views of Responsible Officials and Planned Corrective Action: Management concurs with the finding and will implement enhanced procedures to ensure internal controls support the timely and accurate reporting of student status, program, and completion information to the National Student Loan Data System (NSLDS). For each National Student Clearinghouse (NSC) file submitted, students with status, program, or completion changes will be systematically identified and flagged for review. Registrar staff will conduct a targeted, sample-based review of these flagged records directly within NSLDS to verify that data transmitted from NSC was received, processed, and reflected accurately. All policies and procedures governing enrollment reporting and the processing of student status, program, and completion changes will be reviewed, revised as necessary, and formally implemented no later than April 1, 2026, to align with this corrective action.

View Audit 382241

Finding 1169296 (2025-002)

Material Weakness 2025

Columbus State Community College

OH

Student Financial Aid

Condition: Columbus State Community College did not report student status changes accurately for certain students who withdrew during the year. Planned Corrective Action: As a solution to this issue, the Enrollment Services Operations office at Columbus State Community College, currently responsible...

Condition: Columbus State Community College did not report student status changes accurately for certain students who withdrew during the year. Planned Corrective Action: As a solution to this issue, the Enrollment Services Operations office at Columbus State Community College, currently responsible for National Student Clearinghouse (NSC) reporting, will create a report to monitor for any post-semester enrollment changes that occur due to processes such as end-of-semester grade adjustments or the retroactive withdrawal and administrative withdrawal, to make sure that status changes are reported to the NSC in a timely manner. This report will be monitored, and updates will be made monthly, like the enrollment verification reporting cadence that happens during the semester. Contact person responsible for corrective action: Dina Galley Anticipated Completion Date: 03/01/2026

View Audit 382234

Finding 1169295 (2025-002)

Material Weakness 2025

Monterey Peninsula Community College District

CA

Student Financial Aid

Views of Responsible Officials and Corrective Action Plan The District has implemented a new, fully integrated enterprise resource planning system. This system improves internal controls for data management, enabling us to verify and update enrollment data reported to NSLDS more quickly and accurate...

Views of Responsible Officials and Corrective Action Plan The District has implemented a new, fully integrated enterprise resource planning system. This system improves internal controls for data management, enabling us to verify and update enrollment data reported to NSLDS more quickly and accurately.

View Audit 382233

Finding 1169290 (2025-001)

Material Weakness 2025

Monterey Peninsula Community College District

CA

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Views of Responsible Officials and Corrective Action Plan Each Return of Title IV calculation will be supported by verifiable supporting reports or information demonstrating the number of calendar days used in the calculation. During the annual New Year Roll, all date fields will be manually reviewe...

Views of Responsible Officials and Corrective Action Plan Each Return of Title IV calculation will be supported by verifiable supporting reports or information demonstrating the number of calendar days used in the calculation. During the annual New Year Roll, all date fields will be manually reviewed to ensure default system values are appropriate and consistent with the academic calendar. This information will be reviewed by supervisory personnel independent of the staff member preparing the dates and calculations.

View Audit 382233

Finding 1169285 (2025-001)

Material Weakness 2025

Southwestern Community College District

CA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Management's Reponse: We concur. View of Responsible Offiicals and Corrective Action Plan The Financial Aid department has strengthened R2T4 compliance through staff training, system validation, deadline tracking, peer reviews, and internal audits. The Director will also conduct an annual comprehens...

Management's Reponse: We concur. View of Responsible Offiicals and Corrective Action Plan The Financial Aid department has strengthened R2T4 compliance through staff training, system validation, deadline tracking, peer reviews, and internal audits. The Director will also conduct an annual comprehensive review to assess processes, staffing, and systems to ensure ongoing compliance and improvement. Implementation Date: September 2025

View Audit 382230

Finding 1169279 (2025-004)

Material Weakness 2025

Lewis & Clark Community College District 536

IL

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

Procedures are currently in place to comply with the requirement to send Direct Loan notifications within the regulatory time frame. To support this, the responsible team member will have a weekly reminder added to their Lewis & Clark Outlook work calendar to prompt timely notifications. Management ...

Procedures are currently in place to comply with the requirement to send Direct Loan notifications within the regulatory time frame. To support this, the responsible team member will have a weekly reminder added to their Lewis & Clark Outlook work calendar to prompt timely notifications. Management will also add a weekly reminder to one of the office managers' calendars to assist with ongoing monitoring and compliance checks. Person(s) Responsible: Angela Weaver Timing for Implementation: November 7, 2025

View Audit 382227

Finding 1169278 (2025-003)

Material Weakness 2025

Lewis & Clark Community College District 536

IL

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

The Financial Aid office conducted a comprehensive internal review in Spring 2025 to verify that our procedures were consistently followed. As a result, management corrected a student’s loan proration calculation to be consistent with current practices, regarding truncating rather than rounding the ...

The Financial Aid office conducted a comprehensive internal review in Spring 2025 to verify that our procedures were consistently followed. As a result, management corrected a student’s loan proration calculation to be consistent with current practices, regarding truncating rather than rounding the fractional percentage (decimal) of loan eligibility for students receiving one-semester loans in their last semester of study. Management corrected the loan proration calculation in accordance with current procedures, and the loan amount was adjusted accordingly, resulting in the institution returning $64 in Federal Unsubsidized loan funds to Federal Student Aid. The student was eligible only for unsubsidized loans. Person(s) Responsible: Angela Weaver Timing for Implementation: November 21, 2025

View Audit 382227

Finding 1169259 (2025-001)

Material Weakness 2025

Point Loma Nazarene University and Subsidiary

CA

Student Financial Aid Cash Management Significant Deficiency

TO COME FROM CLIENT!

View Audit 382222

Finding 1169151 (2025-002)

Material Weakness 2025

Alamo Community College District

TX

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Assistance Listing No. Various Views of Responsible Officials and Planned Corrective Actions The exception identified was due to the implementation of the new mobile application which should not have allowed withdrawal functionality to bypass an academic adviso...

Student Financial Assistance Cluster – Assistance Listing No. Various Views of Responsible Officials and Planned Corrective Actions The exception identified was due to the implementation of the new mobile application which should not have allowed withdrawal functionality to bypass an academic advisor when withdrawing from all courses. Management identified the mobile application withdrawal capability and has already performed targeted reviews of students who withdrew via the app and will continue to capture future app withdrawals and perform R2T4 review and calculations accordingly. Responsible Persons Heidi Granger – Associate Vice Chancellor, Financial Aid Michelle Hill – Director, Technical Support, Financial Aid Amber Aboud – Associate Director, Compliance, Financial Aid Sarah Cuellar – Associate Director, Financial Aid Planned completion date for corrective action plan Completed during audit review - December 2025

View Audit 381992

Finding 1169147 (2025-001)

Material Weakness 2025

Alamo Community College District

TX

Internal Control / Segregation of Duties Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Views of Responsible Officials and Planned Corrective Actions Student Financial Aid has implemented exception reports to monitor students whose enrollment status has changed after initial disbursement while the attending hours fun...

Student Financial Assistance Cluster – Assistance Listing No. Various Views of Responsible Officials and Planned Corrective Actions Student Financial Aid has implemented exception reports to monitor students whose enrollment status has changed after initial disbursement while the attending hours functionality is turned off due to the Banner student system defect. This review will ensure timely identification and evaluation of Pell Grant eligibility eliminating the over-awarding of the Pell Grant award amount. Responsible Persons Michelle Hill – Director, Technical Support, Financial Aid Planned completion date for corrective action plan Completed during audit review - December 2025

View Audit 381992

Finding 1169093 (2025-001)

Material Weakness 2025

Bellin College, Inc.

WI

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

The institution implemented adequate oversight to ensure the dates and the student information match NSLDS. To achieve this, the institution has started following up every NSLDS report-run with monitoring to visually confirm the correct data shows up in NSLDS within the required timeframe. The insti...

The institution implemented adequate oversight to ensure the dates and the student information match NSLDS. To achieve this, the institution has started following up every NSLDS report-run with monitoring to visually confirm the correct data shows up in NSLDS within the required timeframe. The institution will keep documentation of the audits and will audit 100% of the records until confidence is gained that the process is working and NSLDS reporting is compliant.

View Audit 381839

Corrective Action Plans

Filters