Corrective Action Plans

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Condition: The University did not have controls in place to ensure that the required due diligence review was completed in the last two-year period related to the current established contract. Planned Corrective Action: In order to ensure that the terms of the consumer accounts offered through UC’s ...
Condition: The University did not have controls in place to ensure that the required due diligence review was completed in the last two-year period related to the current established contract. Planned Corrective Action: In order to ensure that the terms of the consumer accounts offered through UC’s Tier 1 banking agreement are not inconsistent with the best financial interest of students who choose to open an account, UC Campus Services will, at a minimum, every 2 years, beginning October 2025: a. Conduct a due diligence review to ascertain whether the fees imposed under the current agreement are consistent with or below prevailing market rates. a. This will be accomplished by downloading and comparing “consumer schedule of fees” documents from UC’s current provider as well as several local competitors (e.g. US Bank, Fifth Third Bank, Chase Bank, Superior Credit Union). b. Ensure that termination provisions are maintained in the active agreement. These provisions are listed in the current agreement under Exhibit G. 4. (g). (1). In addition, the university will organize a Title IV compliance working group to meet monthly to review any communications or new requirements published by the U.S. Department of ED, State of Ohio, or other regulatory agencies. This core working group will be comprised of members of the Student Financial Aid Office, the Office of the Bursar, and the Office of the Controller, the three offices primarily responsible for awarding, disbursing, and drawing down funds related to the Title IV programs. This group will be responsible for communicating any changes to institutional responsibilities to other university partners who may need to review or revise policies and procedures based on the regulatory changes. Contact person responsible for corrective action: Neal Stark for the specific remedy for the due diligence review, Leigh Jackson for the compliance working group. Anticipated Completion Date: 10/31/2025 and every 2 years thereafter
Finding 2025-003: In order to ensure proper compliance with the return of Title IV Funds, the CFO and Controller have updated the return to Title IV (R2T 4) workbook to include the correct rounding method per federal regulation and the Federal Student Aid Handbook. Documentation of each calculation ...
Finding 2025-003: In order to ensure proper compliance with the return of Title IV Funds, the CFO and Controller have updated the return to Title IV (R2T 4) workbook to include the correct rounding method per federal regulation and the Federal Student Aid Handbook. Documentation of each calculation will now include evidence of rounding verification as part of the R2T4 process. Additionally, the Controller will obtain annual training on current Department of Education requirements, including proper rounding and calculation methodologies.
Finding 2025-001: In order to ensure proper compliance with reporting student enrollment statuses to the National Student Loan Data System, the CFO, Controller, and Director of Student Records will familiarize themselves with federal reporting deadlines and create an improved internal system to moni...
Finding 2025-001: In order to ensure proper compliance with reporting student enrollment statuses to the National Student Loan Data System, the CFO, Controller, and Director of Student Records will familiarize themselves with federal reporting deadlines and create an improved internal system to monitor and report student enrollment changes on a timely basis. The CFO, Controller, and Director of Student Records will explore enhanced monitoring controls such as designating a second reviewer to verify that all files were transmitted and accepted by NSC within required timeframes and implementing an internal tracking log to record the submission and confirmation dates for each roster file.
Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-002 Condition: For 5 of 25 students tested in the sample, the student’s status was reported late to the National Student Loan Data System (NSLDS). The sample was not a statistically valid sample. Corre...
Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-002 Condition: For 5 of 25 students tested in the sample, the student’s status was reported late to the National Student Loan Data System (NSLDS). The sample was not a statistically valid sample. Corrective Action Plan : The Registrar’s office generates enrollment reports every three (3) weeks and they are sent to NSLDS. These reports allow for frequent degree of enrollment reporting to correct this type of error. These changes are in place and have taken effect immediately. Name(s) of Contact Person(s) Responsible for Corrective Action: Rocio De Leon, Registrar Anticipated Completion Date: Immediately Joy E. Brathwaite, MBA MSA Vice President for Finance and Administration Dated: 12/4/2025
Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-001 Condition: The University did not have evidence or documentation available to support the control/review process for return of Title IV calculations. Corrective Action Plan : The University will co...
Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-001 Condition: The University did not have evidence or documentation available to support the control/review process for return of Title IV calculations. Corrective Action Plan : The University will continue to review and adhere to our procedures for refunding awards, and the Financial Aid office will formally document the weekly review of the Return of Title IV funds. Name(s) of Contact Person(s) Responsible for Corrective Action: La Royce Housley, Director of Financial Aid Anticipated Completion Date: Immediately Joy E. Brathwaite, MBA MSA Vice President for Finance and Administration Dated: 12/4/2025
Corrective Action Plan: The University will continue to improve upon Enrollment Reporting as well as continue with all of the changes previously identified and corrected. The University will ensure that the Received Date by NSLDS is within the 60 day compliance reporting requirement. With respect to...
Corrective Action Plan: The University will continue to improve upon Enrollment Reporting as well as continue with all of the changes previously identified and corrected. The University will ensure that the Received Date by NSLDS is within the 60 day compliance reporting requirement. With respect to the reporting of Program Lengths in error, the University took steps to update the processes associated with that activity subsequent to the issuance of the report containing the prior year Single Audit finding 2024-001. Upon consultation with the Office of the Provost and the appropriate Deans of the affected Colleges, the program length for the Master’s programs at the University was updated to two (2), for those programs between 30 and 36 credit hours in length; and three (3) academic years, for those whose minimum credit hours exceeds 36 credit hours, which will meet a reasonable progression to such degree. The Office of Registrar updated all such programs to reflect the decision for the University in November 2024. The students noted in the 2025-001 finding ceased to be active prior to the updated process’ implementation and were excluded from the reporting population. All activity contained in the sample selection for changes after the implementation date were handled in accordance with the regulations. One of those students reenrolled and the Program Length was updated to correctly reflect the student’s new program. The University will continue to monitor this area for any future discrepancies. Responsible Parties: The University has identified the Registrar – Paula Brown along with the Director of the Office of Financial Aid – James Hubener as the responsible parties to ensure continued monitoring of the activity on these types of items to ensure timely and accurate reporting to NSLDS. Estimated Completion Date: November 30, 2024
SIGNIFICANT DEFICIENCY 2025-001 Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Return to Title IV Condition Of the 37 students tested for Return to Title IV procedures, 2 were determined to have had errors in their calculation. Recommendat...
SIGNIFICANT DEFICIENCY 2025-001 Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Return to Title IV Condition Of the 37 students tested for Return to Title IV procedures, 2 were determined to have had errors in their calculation. Recommendation We recommend that the College review and update its policies to ensure that accurate Return to Title IV calculations are completed. Comments on the Finding For the issue with an institutional charge incorrectly considered in the R2T4 calculation, this was due to a Federal Direct Parent PLUS Loan that was processed and a refund to the parent. Only seven of these loans were processed in the aid year of 2024-25, and there were no other R2T4 situations that involved a Federal Direct Parent PLUS Loan. The refund to the parent was shown at the top of the Banner form while student refunds show at the bottom of the Banner form. Due to the rarity of these loans being included in the calculation and the variation of where this charge is shown in Banner, this was missed. Barton personnel are now aware of where to look for this in these very rare cases. For the situation where the incorrect starting date was identified, there was human error when that was entered. Barton does have a quality assurance process to double check all dates on the Banner withdrawal form, and the R2T4 calculation spreadsheet, however, this review will now extend to checking the enrollment dates in a second Banner form. Action Taken Since the 2024-25 aid year was still open, both instances were corrected. Barton’s Director of Financial Aid has made all personnel aware of the issues and has revised the quality assurance review to watch for these issues.
The Institution has reviewed the details of the finding and determined the error to be due to human error and the responsibility of the Institution. Subsequent to the audit, the Institution refunded $350 in 2023-2024 Federal Pell Grant program funds on behalf of student #20 (VR). In addition the Ins...
The Institution has reviewed the details of the finding and determined the error to be due to human error and the responsibility of the Institution. Subsequent to the audit, the Institution refunded $350 in 2023-2024 Federal Pell Grant program funds on behalf of student #20 (VR). In addition the Institution refunded $419 in 2024-2025 Federal Pell Grant program funds on behalf of student #2 (EL). These two students over-award was due to a schedule or grade change that took place after the start of student’s term or payment period. The Institution will implement reporting from our SIS to monitor schedule or grade changes that take place after the start of a student’s term or payment period.
Recommendation: We recommend Mitchell Hamline School of Law review its reporting procedures to ensure the students' statuses are timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in respo...
Recommendation: We recommend Mitchell Hamline School of Law review its reporting procedures to ensure the students' statuses are timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Starting in January 2026, the Registrar’s Office will be performing the monthly reporting. In preparation for this change in responsibilities, Student Financial Aid has provided training to multiple individuals in the Registrar’s Office along with detailed documented procedures. Student Financial Aid and the Registrar’s Office will coordinate responses/requests from NSLDS. Name(s) of the contact person(s) responsible for corrective action: Sheila Tolley, Executive Registrar and Nick Anderson, Director of Financial Aid Planned completion date for corrective action plan: Spring Semester 2026
Finding 2025-003 Condition Of the sample of 25 disbursements, seven students tested did not receive proper notification of the student's right, or the parent's right to cancel any portion of the loans to be distributed. The sample was not a statistically valid sample. Corrective Action Plan To addre...
Finding 2025-003 Condition Of the sample of 25 disbursements, seven students tested did not receive proper notification of the student's right, or the parent's right to cancel any portion of the loans to be distributed. The sample was not a statistically valid sample. Corrective Action Plan To address this issue, the ERP notification process has been updated to ensure students receive clear and compliant communications regarding Direct Loan disbursements. Name(s) of Contact Person(s) Responsible for Corrective Action: Susan Collins, Director of Financial Aid Completion Date: October 17, 2025 Linda Scholting CFO 10/29/2025 Doc Management Response: Management has updated notification processes to ensure appropriate and timely notifications are sent to students.
Finding 2025-002 Condition Of 25 students tested, the status date for one selected student was not reported in a timely manner on the campus level in the National Student Loan Data System (NSLDS). The sample was not statistically valid. Corrective Action Plan To address this issue, the Registrar’s O...
Finding 2025-002 Condition Of 25 students tested, the status date for one selected student was not reported in a timely manner on the campus level in the National Student Loan Data System (NSLDS). The sample was not statistically valid. Corrective Action Plan To address this issue, the Registrar’s Office will adjust the final spring submission date or add a fifth submission to ensure all spring updates are captured. This action resolves timing gaps caused by the non-term summer and the 60+ day interval between spring and fall semesters. Name(s) of Contact Person(s) Responsible for Corrective Action: Denise Ellis, Registrar Anticipated Completion Date: Spring submission dates will be modified or added by November 1, 2025 Linda Scholting CFO 10/29/2025 Management Response: Management has adjusted processes to ensure all student updates are correctly captured.
Finding 2025-001 Condition During the year, there were no documented internal controls in place over the Title IV refund calculations. In the sample of 5 students who withdrew from the University, there was one student for whom the return was miscalculated. The result was too much aid being refunded...
Finding 2025-001 Condition During the year, there were no documented internal controls in place over the Title IV refund calculations. In the sample of 5 students who withdrew from the University, there was one student for whom the return was miscalculated. The result was too much aid being refunded. The sample was not statistically valid. Corrective Action Plan To address this issue, the Title IV Return of Funds Policy has been updated to strengthen accountability and compliance. All R2T4 calculations will be completed by the Financial Aid Counselor and reviewed by the Director, with signatures documenting internal controls. A checklist and quarterly reviews will ensure accuracy, and ERP integration within Ellucian Colleague, set for full implementation by October 31, 2025, will automate calculations and improve compliance monitoring. Name(s) of Contact Person(s) Responsible for Corrective Action: Susan Collins, Director of Financial Aid Anticipated Completion Date: October 31, 2025 Linda Scholting CFO 10/29/2025
Management agrees with the auditors’ finding and their recommendation. In August 2025, $712 of Federal Pell Grant funds were awarded to the first student in question and $260 of Federal Pell Grant funds were returned to the Department of Education for the fifth student in question. Since the remaini...
Management agrees with the auditors’ finding and their recommendation. In August 2025, $712 of Federal Pell Grant funds were awarded to the first student in question and $260 of Federal Pell Grant funds were returned to the Department of Education for the fifth student in question. Since the remaining three students were due additional Unsubsidized Federal Direct Loan funds, the College awarded additional institutional aid of $62, $93, and $93 to students two, three, and four, respectively. The Student Financial Aid Director will communicate with the Online Education Director and/or the Registrar to verify semester and enrollment dates and attend additional training webinars on R2T4 calculations hosted by the Department of Education. Anticipated Completion Date:The corrective action was completed in August 2025. Contact Person Brian Rains, Director of Financial Aid 417-268-6045
Recommendation: We recommend the College evaluate its procedures and policies around reporting enrollment changes to NSLDS to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action tak...
Recommendation: We recommend the College evaluate its procedures and policies around reporting enrollment changes to NSLDS to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Augustana intends to modify the NSC/NSLDS monthly data file to ensure that campus and program enrollment dates are pulled from the appropriate data fields in the student information system. Additionally, Augustana intends to implement a step in the withdrawal process to ensure the change in status is reported accurately and timely. Name of the contact person responsible for corrective action: John Cage at johncage@augustana.edu Planned completion date for corrective action plan: January 30, 2026
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Will need to meet with academic records and determine if Doctorate program Dissertation 1-hour course can be coded and reported as full time to NSLDS Person Responsible for Corrective Action Plan: ...
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Will need to meet with academic records and determine if Doctorate program Dissertation 1-hour course can be coded and reported as full time to NSLDS Person Responsible for Corrective Action Plan: Academic Records / Regina Bolding Harned - Registrar / Allison Sullivan – Director of Financial Aid Anticipated Date of Completion: 12/5/25
KCU 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 KCU’s student information system to ensure that all dates and information submitted for the m...
KCU 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 KCU’s student information system to ensure that all dates and information submitted for the month is accurate and timely. Contact Person: Cindy Miller Anticipated Completion Date: August 15, 2025
It is our understanding that the issue is occurring for many instituations and appears to be due to changes in processes at the National Clearinghouse. We will monitor steps taken and updates made to maintain awareness of any resolution to the issue made at the Clearinghouse. We will also develop an...
It is our understanding that the issue is occurring for many instituations and appears to be due to changes in processes at the National Clearinghouse. We will monitor steps taken and updates made to maintain awareness of any resolution to the issue made at the Clearinghouse. We will also develop an internal process to review student status effective dates as reflected in NSLDS and make updates as needed.
Contact Person: Ron Dempsey, Controller Views of Responsible Officials and Planned Corrective Action: Management concurs with the finding. The College experienced some turnover during the year. The new director was unaware that the Cost of Attendance was not being updated when a change in the award ...
Contact Person: Ron Dempsey, Controller Views of Responsible Officials and Planned Corrective Action: Management concurs with the finding. The College experienced some turnover during the year. The new director was unaware that the Cost of Attendance was not being updated when a change in the award was submitted COD due to a change in the student’s schedule. The director is now aware that these changes must be updated manually in COD and has implemented procedures to ensure that the COA is reviewed whenever a revision to the student award is submitted to COD. The college will also confer with the software vendor to determine if any settings in the student information need to be corrected for this update to be automated. The new director of financial aid has been through substantial training in the last six months to better understand how the college’s software communicates with COD and has implemented procedures to ensure the timely submission of disbursements to COD after the disbursements have been made in the student information system. Anticipated Completion Date: Prior records with issues were corrected on September 1, 2025 and ongoing monitoring is taking place
Contact Person: Ron Dempsey, Controller Views of Responsible Officials and Planned Corrective Action: Management concurs with the finding. This was an unusual circumstance where a student was withdrawn from the college before they were awarded any federal aid. The director has put in place procedure...
Contact Person: Ron Dempsey, Controller Views of Responsible Officials and Planned Corrective Action: Management concurs with the finding. This was an unusual circumstance where a student was withdrawn from the college before they were awarded any federal aid. The director has put in place procedures to review the eligibility for federal aid of any student who withdraws to determine whether a post withdrawal disbursement is appropriate. Anticipated Completion Date: January 1, 2026
Improper Time & Effort Reporting Condition: 2 CFR 200.430 of the Uniform Guidance mandates that personnel compensation charged to federal awards must be based on records that accurately reflect the work performed. When an employee works on multiple cost objectives (e.g., multiple awards or activitie...
Improper Time & Effort Reporting Condition: 2 CFR 200.430 of the Uniform Guidance mandates that personnel compensation charged to federal awards must be based on records that accurately reflect the work performed. When an employee works on multiple cost objectives (e.g., multiple awards or activities), this often necessitates the use of personnel activity reports or similar timekeeping documents to accurately allocate salaries and wages. During the audit, we found that proper personnel activity reports were not being maintained for multiple cost objective employees charged to Title IV and to the Special Education Cluster. While we were able to support that the amounts charged to the grants were reasonable, through review of the employee's Outlook calendars, daily schedules, etc., the documentation required by federal guidance was not available. We recommend that management provide training to all multiple cost objective employees on how to properly document their time and then to Implement oversite procedures requiring that those personnel activity reports be submitted to management for review on a monthly basis. Corrective Action: The District has begun training all staff and grant Directors on the proper documentation required to properly support the time and effort employees spend on various grants. In addition, the Grant Director will begin reviewing this documentation on a periodic basis, to ensure complete compliance. Contact Person Responsible for Corrective Action: Chanda Cleaves, Executive Director of Finance Completion Date: This issue will be corrected moving forward.
In response to the findings from the 2025 ACFR, MLVR Charter school will be submitting a CFM CAP to homeroom. The CAP will address the following: 1. Reimbursement requests will be submitted at a minimum quarterly otherwise every two months. 2. Accounting software is updated and reviewed to ensure bu...
In response to the findings from the 2025 ACFR, MLVR Charter school will be submitting a CFM CAP to homeroom. The CAP will address the following: 1. Reimbursement requests will be submitted at a minimum quarterly otherwise every two months. 2. Accounting software is updated and reviewed to ensure budgeted amounts and carryover funds are properly recorded throughout the fiscal year.
Condition: During our review of the return of Title IV funds, we noted that there were 4 students in the fall that were reported late. Criteria: When a recipient of Title IV funds withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, t...
Condition: During our review of the return of Title IV funds, we noted that there were 4 students in the fall that were reported late. Criteria: When a recipient of Title IV funds withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must perform a Return of Title IV Funds calculation to determine the amount of Title IV assistance the student earned as of the student’s withdrawal date. Cause: Student Financial Aid personnel did not have the fall end of term submission set timely. Effect: Funds required to be sent back to the Department of Education are late. Perspective: Significant personnel changes were made at the end of the June 30, 2024 year and the fall term was the first time submitting the end of term report. Spring submissions were all timely. Recommendation: We recommend training of Student Financial Aid personnel on the rules and regulations over return of funds. In addition, we recommend that submissions dates are pre-determined and verified that they will be timely. Views of Responsible Officials and Planned Corrective Actions: Dodge City Community College staff involved are undergoing training to learn requirements. Processes and procedures have been developed to ensure timely calculations and refunds. In addition, they have changed submission dates to avoid issues in the future.
Condition: We examined a sample of Title IV aid recipients to verify that information reported on the Enrollment Reporting roster file sent to the National Student Loan Data System (NSLDS) matched the student's academic files and found instances where students received Title IV aid during a semester...
Condition: We examined a sample of Title IV aid recipients to verify that information reported on the Enrollment Reporting roster file sent to the National Student Loan Data System (NSLDS) matched the student's academic files and found instances where students received Title IV aid during a semester but the status of withdrawn or graduate were not reported timely on the NSLDS Enrollment Reporting roster files sent during that semester. Criteria: Per the NSLDS Enrollment Reporting Guide, a school should report all students that NSLDS includes in its request to the school on a roster file. This includes timely and accurate reporting of the status of the student of withdrawn or graduate. Cause: The status of the students were not timely reported to NSLDS. Effect: Students could potentially not be placed in grace or repayment status when they should be. Perspective: All withdrawn students tested were reported accurately, but there were a few fall students that were not submitted timely. Spring students tested were timely. The new Director came on in at the end of the June 30, 2024 year and worked to correct the reporting. The fall period was the first time through the submission, but by Spring, no issues remained. Recommendation: The College has moved up the initial reporting date after semester the semester ends to correct the timeliness issue. Views of Responsible Officials and Planned Corrective Actions: Dodge City Community College staff involved in enrollment reporting to the NSLDS agree with this finding and have already taken steps to ensure timely reporting in the future.
Condition: The School did not have a documented Direct Loan quality assurance program in place during a significant portion of the year under audit. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student as...
Condition: The School did not have a documented Direct Loan quality assurance program in place during a significant portion of the year under audit. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student assistance programs. The School coordinated with this third-party processor to ensure that a documented quality assurance program was put into place in March 2025 and regularly exercised for compliance purposes. All documentation will be maintained. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: March 2025
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