Corrective Action Plans

Finding 524632 (2024-001)

None 2024

KY

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Bellarmine University agrees with the auditors’ finding and recommendations. The following corrective action will be taken: The University will return $1,779 in federal student financial aid to the United States Department of Education (USED) which represents the updated R2T4 accounting for the corr...

Bellarmine University agrees with the auditors’ finding and recommendations. The following corrective action will be taken: The University will return $1,779 in federal student financial aid to the United States Department of Education (USED) which represents the updated R2T4 accounting for the correct withdrawal dates in the Spring 2024 semester. There will be an additional review process that will include validation from financial and student accounts to verify calculations before finalizing returns of funds. Financial Aid will provide an additional R2T4 form that has date of determination and LDA. Financial Aid will review that all dates and calculations match after the R2T4 has been completed and before handing off to student accounts. Student accounts will then review to confirm all dates and amounts match before processing the return of funds. April Tretter, Director of Financial Aid, expected implementation date 2.26.25.

View Audit 344071 Questioned Costs: $1

Finding 524630 (2024-004)

Significant Deficiency 2024

Keystone College

PA

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Management will implement a thorough review process of calculations to ensure proper dates are being used. Additionally, management will review update routines and communication of student enrollment status to ensure timely cacluation and return of any unearned portion of grant or loan funds to the...

Management will implement a thorough review process of calculations to ensure proper dates are being used. Additionally, management will review update routines and communication of student enrollment status to ensure timely cacluation and return of any unearned portion of grant or loan funds to the appropriate Title IV program in accordance with federal regulations.

View Audit 344059 Questioned Costs: $1

Finding 524628 (2024-002)

Significant Deficiency 2024

Keystone College

PA

Student Financial Aid Reporting

Management has strengthened controls and trained staff to ensure compliance with cash management practices for future federal awards.

View Audit 344059

Finding 524609 (2024-003)

Significant Deficiency 2024

Marymount University

VA

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

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanatio...

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately 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: The findings stemmed from how the Student Information System (SIS) transmitted graduation dates and the accuracy of submission files. Our previous SIS was unable to determine the correct graduation dates, leading to incorrect data uploads to the National Student Clearinghouse (NSC). We reviewed the NSC error report and made individual corrections. Unfortunately, we missed the data transmission at the beginning of the month and had to wait for the corrections to be sent to the National Student Loan Data System (NSLDS) the following month. Additionally, we did not conduct a comprehensive review of the file to ensure that all data matched after the upload. Marymount has transitioned to a new SIS starting in Fall 2024. We are working closely with the NSC during this transition to provide more timely and accurate data. We have also improved our processes by having multiple staff members review data files before posting them to the NSC, ensuring that every data point is correct. Furthermore, we have joined user groups related to our SIS and NSC reports to stay informed about changes made by the SIS vendor and to be aware of potential complications faced by other universities. Any errors identified during the data upload to the NSC will be corrected within 2-3 business days. This process will ensure that the enrollment status is certified within 60 days and that all dates match. If we are unable to update the NSC before the file is submitted to the NSLDS, we will collaborate with our Financial Aid department to manually update the NSLDS. Name(s) of the contact person(s) responsible for corrective action: Courtney Carey, University Registrar, 703-284-1523 Planned completion date for corrective action plan: March 2025

View Audit 344056

Finding 524608 (2024-002)

Significant Deficiency 2024

Marymount University

VA

Student Financial Aid Subrecipient Monitoring

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safegu...

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has prepared a separate Corrective Action Plan document in response to this finding due to the sensitivity. Each requirement noted as a deficiency within the finding is address separately and appropriate response is being taken. Name(s) of the contact person(s) responsible for corrective action: Carl Whitman, Associate Vice President and Chief Information Officer (703-526-6901) Planned completion date for corrective action plan: Action plan completed on February 18, 2025.

View Audit 344056

Finding 524579 (2024-002)

Significant Deficiency 2024

Saint Mary's University of Minnesota

MN

Student Financial Aid Reporting Significant Deficiency

Student Status Changes Condition The change in student status for 8 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, the students were ultimately reported to the NSLDS. Correc...

Student Status Changes Condition The change in student status for 8 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, the students were ultimately reported to the NSLDS. Corrective Action Plan: The institution launched the Jenzabar student information system in July 2023. As part of this transition, institution discontinued our branch with the National Student Clearinghouse (NSC). This closure led to recurring reporting errors each month as the NSC worked to correct the branch closure data. Currently, one person is responsible for submitting the university's monthly enrollment and degree verification reports. There has been a significant learning curve as the instruction worked to address NSC errors, Jenzabar implementation errors, Jenzabar processes, and our own SMU practices. The learning was complemented by the work to file the FVT/GE reporting in fall 2024. Starting January 1, 2025, the institution has updated processes to minimize the need for secondary reviews of reported graduations at NSC. The institution implemented a tracking system to identify situations that consistently lead to errors in the graduation reporting process. The financial aid department has been provided access to NSC to review and address errors needing to be fixed directly in NSLDS. The financial aid department will audit reports of graduates in NSLDS against those submitted through NSC. The financial aid team will partner with registrar on corrections and evaluate if access to NSLDS for members of the registrar team would also make sense.

View Audit 344025

Finding 524574 (2024-001)

None 2024

Saint Mary's University of Minnesota

MN

Student Financial Aid Matching / Level of Effort / Earmarking HUD Housing Programs

Return of Title IV Funds Condition The federal aid refunds for one of the students tested was not returned within 45 days from the withdrawal date. Corrective Action Plan: The intuition has since resolved these issues and have reports and practices in place to monitor and preform R2T4s. The fin...

Return of Title IV Funds Condition The federal aid refunds for one of the students tested was not returned within 45 days from the withdrawal date. Corrective Action Plan: The intuition has since resolved these issues and have reports and practices in place to monitor and preform R2T4s. The financial aid office is now staffed with a qualified director that is able to monitor and preform R2T4s in a timely manner. There was also a deficiency with getting accurate information from the new student information system, Jenzabar that did cause issues with identifying student drops. The director has worked with the IT department in developing a report that is ran on a weekly basis to catch all changes to enrollment. More staff in the coming year will be trained on how to preform R2T4s so that there will be more than one person qualified to preform R2T4s for the institution.

View Audit 344025

Finding 524571 (2024-102)

Significant Deficiency 2024

Aroostook Area Agency on Aging INC

ME

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

The Agency will implement appropriate processes and controls to ensure the Schedule of Federal Awards contains complete and accurate data.

View Audit 344021

Finding 524568 (2024-003)

None 2024

Oregon College of Oriental Medicine

OR

Special Tests & Provisions Student Financial Aid Eligibility

Finding: 2024-003 Special Tests and Provisions Department’s Response: We concur Corrective Action: Since the closure of the College will result in no further federal work study activity, no immediate corrective action is considered necessary. Contact: Phil Lundberg Anticipated Completion Date: I...

Finding: 2024-003 Special Tests and Provisions Department’s Response: We concur Corrective Action: Since the closure of the College will result in no further federal work study activity, no immediate corrective action is considered necessary. Contact: Phil Lundberg Anticipated Completion Date: Immediately

View Audit 344009

Finding 524567 (2024-002)

None 2024

Oregon College of Oriental Medicine

OR

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding: 2024-002 Reporting Department’s Response: We concur Corrective Action: Since the closure of the College will result in no further student loan activity, no immediate corrective action is considered necessary. Contact: Phil Lundberg Anticipated Completion Date: Immediately

View Audit 344009

Finding 524564 (2024-001)

Significant Deficiency 2024

The Chicago School-Cal INC Dba the Chicago Sch of Pro Psychology

IL

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – The Chicago School Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federa...

Corrective Action Plan – The Chicago School Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had excess cash for the Federal Direct Student Loan program, ranging from $528,450 to $1,238,306, from November 13, 2023, to December 18, 2023. While the excess cash did not exceed the one-percent tolerance of prior year drawdowns, the amounts were not returned within the seven-day period as required. Summary: The College draws a portion of funds for student stipends while award reconciliation is in progress to ensure timely disbursement. An administrative oversight led to excess cash being held longer than allowed. Specifically, the prior stipend drawdown was not netted out when calculating subsequent fund requests, resulting in excess cash being held for 24 business days. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure compliance with the seven-day return requirement. 2. Process Change: Going forward, the College will refrain from drawing funds for student stipends until reconciliations have been fully completed. This will ensure that funds are drawn in alignment with actual disbursement needs, reducing the risk of excess cash. 3. Internal Control Strengthening: The College will enhance internal controls around cash management to ensure that excess cash instances are identified and corrected promptly. 4. Staff Training: All relevant staff will undergo training on revised cash management procedures and the importance of timely reconciliation and returns. 5. Improved Monitoring: The College will implement a more robust monitoring process to track excess cash and ensure compliance with Federal regulations, including daily checks during peak disbursement periods. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343996

Finding 524562 (2024-001)

Significant Deficiency 2024

Pacific Oaks Education Corporation

CA

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – Pacific Oaks Education Corporation Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Guidance of the Department of Education (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title...

Corrective Action Plan – Pacific Oaks Education Corporation Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Guidance of the Department of Education (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had excess cash for the Federal Direct Student Loan program, ranging from $1,335,590 to $4,774,182, from September 6, 2023, to September 13, 2023. The excess cash exceeded the one-percent tolerance of prior year drawdowns, and the funds were not posted to students' ledgers within the three-business-day period as required. Summary: The College draws a portion of funds early to ensure the timely disbursement of stipends to students, while the reconciliation process is still underway. However, the funds were not posted to students’ ledgers within the required three days, leading to a violation of the federal cash management requirements. The issue was related to administrative oversight in the processing of the drawn funds. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure funds are posted to students’ ledgers within the three-business-day requirement. 2. Process Change: The College will refrain from drawing funds early to cover stipends until all necessary reconciliations are completed, ensuring compliance with the required disbursement timeline. 3. Internal Control Strengthening: The College will strengthen internal controls by implementing more rigorous checks to ensure timely posting of funds to students' accounts after drawdowns. 4. Staff Training: Relevant staff members will undergo training on the updated procedures and the importance of timely posting of funds to student ledgers. 5. Improved Monitoring: The College will institute enhanced monitoring and tracking of funds after drawdowns to ensure that the required posting timeframe is consistently met. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343993

Finding 524554 (2024-001)

Significant Deficiency 2024

University of Miami

FL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

UM management acknowledges that the status changes for 5 out of 40 students selected were not reported to NSLDS within the required 60-day timeframe. This delay was caused by unexpected technical issues during the submission process to the National Student Clearinghouse. Corrective Action Plan UM ...

UM management acknowledges that the status changes for 5 out of 40 students selected were not reported to NSLDS within the required 60-day timeframe. This delay was caused by unexpected technical issues during the submission process to the National Student Clearinghouse. Corrective Action Plan UM management has since implemented a new process for reporting submission to bypass the technical issues. Timeline for Action Plan The new process was implemented in March 2024. Responsible JndjviduaJs Allen Augustin, Associate Registrar

View Audit 343977

Finding 524542 (2024-003)

Significant Deficiency 2024

Donnelly College

KS

Student Financial Aid Matching / Level of Effort / Earmarking

Contact Person: Ron Dempsey, Controller Views of Responsible Officials and Planned Corrective Action: The College has procedures in place that are supposed to prevent the awarding of students in verification. The Student Information System (Empower) has a feature for tracking students in verificati...

Contact Person: Ron Dempsey, Controller Views of Responsible Officials and Planned Corrective Action: The College has procedures in place that are supposed to prevent the awarding of students in verification. The Student Information System (Empower) has a feature for tracking students in verification. That tracking system did not prevent the awarding of Title IV aid. Therefore, the college will implement a backup tracking system to help track students in verification. Anticipated Completion Date: March 31, 2025

View Audit 343943

Finding 524524 (2024-004)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding:...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and 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: • Fully implement and utilize existing reporting functionality in Jenzabar for National Student Clearinghouse • Review existing reporting procedures and process configurations for NSC reporting in Jenzabar to ensure that things are working correctly and being reported in a timely manner • Document the full process internally in the Registration and Records department Name(s) of the contact person(s) responsible for corrective action: Chris Cook, Registrar Planned completion date for corrective action plan: January 31, 2025

View Audit 343891

Finding 524514 (2024-002)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

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

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review their records to locate the missing promissory notes. If the signed promissory notes can’t be located, the College should assess if there is sufficient documentation to support...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review their records to locate the missing promissory notes. If the signed promissory notes can’t be located, the College should assess if there is sufficient documentation to support the loan such as repayment history, documentation showing the original payment was accepted by the student, etc. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Subsequent to the audit testing, all Perkins loan MPNs were located and the College is finalizing its assignment of the loans to the Department of Education. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wynne, Interim CFO and Grant Drinnen, Cash and Accounts Receivable Specialist Planned completion date for corrective action plan: January 31, 2025

View Audit 343891

Finding 524509 (2024-001)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with a...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has reviewed and updated its procedures related to the process of reviewing and remitting unclaimed student refund checks. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wynne, Interim CFO Planned completion date for corrective action plan: January 31, 2025

View Audit 343891 Questioned Costs: $1

Finding 524493 (2024-002)

Significant Deficiency 2024

Rogue Community College

OR

Reporting Special Tests & Provisions Student Financial Aid

Finding: 2024-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.063, and 84.268 Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for accurate report...

Finding: 2024-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.063, and 84.268 Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. The support provided by RCC for the student’s last date of attendance did not agree to the student’s withdrawal that had been submitted to NSLDS. Responsible Individuals: Danielle Crouch, Registrar and Analisa Gifford, Assistant Registrar Corrective Action Plan: During the 2023-2024 academic year, we were utilizing an outdated, homegrown Student Information System (SIS). A previously unidentified flaw in the system’s programming logic caused incorrect withdrawal dates to be populated in the National Student Clearinghouse (NSC) report. For the 2024-2025 academic year, we have transitioned to Jenzabar One, an industry-recognized SIS that includes built-in Enrollment Reporting functionality. To ensure accurate reporting moving forward, we are conducting audits of withdrawal dates at the end of each term. With the implementation of this new system and enhanced audit processes, this issue will be fully mitigated. Anticipated Completion Date: June 25, 2025

View Audit 343860

Finding 524468 (2024-001)

Significant Deficiency 2024

The Colleges of Law

CA

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – The Colleges of Law Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Feder...

Corrective Action Plan – The Colleges of Law Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had one instance of excess cash for the Federal Direct Student Loan program, ranging from $172 to $10,314, from March 25, 2024, to April 5, 2024. Although the excess cash did not exceed the one-percent tolerance of prior year drawdowns, the funds were not returned within the required seven-day period. Summary: The College inadvertently retained excess cash for the Federal Direct Student Loan program beyond the seven-day tolerance period due to administrative oversight. The delay in returning the excess cash was attributed to the reconciliation process taking longer than anticipated. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure excess funds are returned to the Secretary within the seven-day tolerance period. 2. Process Change: The College will enhance its reconciliation process to expedite the identification and return of excess cash within the required timeframe. 3. Internal Control Strengthening: The College will implement more rigorous internal controls, including automated alerts and checks, to ensure compliance with cash management requirements. 4. Staff Training: Relevant staff will receive additional training on updated cash management procedures and the importance of timely returning excess cash. 5. Improved Monitoring: The College will introduce enhanced monitoring and tracking mechanisms to ensure that excess cash is promptly identified and returned within the mandated period. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343821

Finding 524441 (2024-001)

Significant Deficiency 2024

McDaniel College and Subsidiary

MD

Questioned Costs Student Financial Aid Subrecipient Monitoring

Finding 2024-001 Condition Finding 2024-001 – Significant Deficiency – Return of Title IV Federal Program – Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency – U.S. Department of Education Pass- Through Entity – Not Applicable ALN Number – 84.063, 84.268 Federal Award Y...

Finding 2024-001 Condition Finding 2024-001 – Significant Deficiency – Return of Title IV Federal Program – Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency – U.S. Department of Education Pass- Through Entity – Not Applicable ALN Number – 84.063, 84.268 Federal Award Year – May 31, 2024 Criteria: The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. In addition, when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine, through a Return of Title IV Funds (R2T4) calculation, the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Corrective Action Plan Corrective Action Planned: {The College agrees with the finding and has taken immediate corrective action to address the finding related to R2T4 calculations. All R2T4 calculations for the related period have been recalculated and reviewed for accuracy. Any noted discrepancies related to the necessary return of funds have been addressed. Enhanced internal controls have been implemented to ensure that the dates entered in the Colleague system aligns with the academic calendar. The College will also institute an internal audit/compliance process for additional verification and monitoring. Identify the specific actions to be taken to eliminate or mitigate the recurrence of the finding. Name(s) of Contact Person(s) Responsible for Corrective Action: Kemia Himon, Financial Aid Director Anticipated Completion Date: 3.3.25

View Audit 343760 Questioned Costs: $1

Finding 524434 (2024-003)

Significant Deficiency 2024

Payne Theological Seminary

OH

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

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in r...

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The seminary will update our current WISP to comply with all requirements and updated standards. Name(s) of the contact person(s) responsible for corrective action: Raymond Ingram Planned completion date for corrective action plan: April 2025

View Audit 343723

Finding 524433 (2024-002)

Significant Deficiency 2024

Payne Theological Seminary

OH

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

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary implemented a process to ensure credit balances are returned timely based on the regulations set forth by the Department of Education. Explanation of disagreement with audit finding: There is no disagreeme...

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary implemented a process to ensure credit balances are returned timely based on the regulations set forth by the Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Through December 2024, Payne issues credits/refunds in two disbursements. In November 2024, the Business Office and Academic Services discussed moving to a single credit/refund disbursement in an effort to avoid potential delays in processing. A decision was made to approve the single credit/refund disbursement process effective Spring 2025. Financial Aid Services was notified and provided a new disbursement schedule. Communication of the change was sent to students November 30, 2024. Person responsible - Maryjo Lewis Planned completion date: The new process in effect beginning Spring 2025 term

View Audit 343723

Finding 524432 (2024-001)

Significant Deficiency 2024

Payne Theological Seminary

OH

Student Financial Aid Reporting Significant Deficiency

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend the Seminary evaluate its procedures and policies around reporting Unsubsidized loan disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding:...

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend the Seminary evaluate its procedures and policies around reporting Unsubsidized loan disbursements to COD 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 finding: The Business Office will post the awarded funds to the accounts in SONIS on the date designated on the disbursement roster. Name(s) of the contact person(s) responsible for corrective action: Razieh Adinehzadeh Planned completion date for corrective action plan: Changes implemented in February 2025.

View Audit 343723

Finding 524425 (2024-001)

Significant Deficiency 2024

Morehouse College

GA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding No. 2024-001 SFA – Enrollment Reporting Federal Program Student Financial Assistance Cluster AL No. 84.268 Federal Direct Student Loans Federal Agency U.S. Department of Education Federal Award Years October 1, 2022 to September 30, 2023 October 1, 2023 to September 30, 2024 Criteri...

Finding No. 2024-001 SFA – Enrollment Reporting Federal Program Student Financial Assistance Cluster AL No. 84.268 Federal Direct Student Loans Federal Agency U.S. Department of Education Federal Award Years October 1, 2022 to September 30, 2023 October 1, 2023 to September 30, 2024 Criteria or Requirement Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS (OMB No. 1845-0035) (Pell, 34CFR 690.83(b)(2); FFEL, 34CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). Condition and Context During our test work, we selected a sample of 40 students that had enrollment status changes during fiscal year 2024. Within our sample, we identified 3 instances where the students’ enrollment status was not properly communicated to National Student Loan Data System (NSLDS). These instances involved students who reported their status changes to the College after the normal reporting period had ended. Cause and Potential Effect Noncompliance due to no control in place to identify late submissions of status changes and ensure that these changes are properly communicated to the NSLDS. This lack of control could result in inaccurate or delayed reporting of student status changes to the NSLDS, potentially affecting loan servicing and compliance with federal regulations. Questioned Cost There were no questioned cost associated with the finding. Corrective Action Plan to Finding 2024-001: Contact person for corrective action: LaKeidra Gilford – Interim Registrar Office of Records and Registration Corrective Action Plan: Morehouse College plan to implement the following to address finding No. 2024-001. • Office of Records and Registration will create a new policy effective July 1, 2025, that will state any medical withdrawals received after the last day of the current term will not be honored. • Office of Records and Registration effective May 2025 will continue the current process with additionally submitting two (2) additional graduation reports each month after the initial report is sent to National Student Clearinghouse to ensure all graduates are captured and reported.

View Audit 343696

Finding 524389 (2024-001)

Significant Deficiency 2024

Kansas Health Science Center, Inc.

IL

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – Kansas Health Science University Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, oth...

Corrective Action Plan – Kansas Health Science University Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: Kansas Health Science University (KHSU) had excess cash for the Federal Direct Student Loan program, including $268,278 from July 12, 2023, to July 19, 2023, and amounts ranging from $2,204 to $13,385 from April 8, 2024, to April 23, 2024. For the first period, the excess cash exceeded the one-percent tolerance of prior year drawdowns and was not returned within the three business-day period. For the second period, although the excess cash did not exceed the one-percent tolerance, amounts were not returned within the seven-day period as required. Summary: KHSU identified two instances of excess cash due to delays in returning unused funds. The Funds were not returned to ED withing the required number of days, leading to a violation of the federal cash management requirements. The issue was related to an administrative oversight related to the timing of the return of drawn funds. Corrective Action Planned or Taken: 1. Procedure Update: KHSU will update its cash management procedures to ensure compliance with both the three-day and seven-day return requirements for excess cash. 2. Process Change: KHSU will implement a process to immediately review and reconcile drawdowns with disbursement needs. Drawdowns will be based strictly on reconciled disbursement schedules to prevent excess cash. 3. Internal Control Strengthening: Internal controls will be enhanced to include automated alerts for identifying excess cash and triggering prompt corrective actions. 4. Staff Training: Financial aid and accounting staff will undergo targeted training on Federal cash management regulations, focusing on the prevention and timely resolution of excess cash. 5. Improved Monitoring: KHSU will establish daily monitoring of cash balances during peak disbursement periods and periodic reviews to ensure ongoing compliance with Federal regulations. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

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