Corrective Action Plans

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Name of Responsible Individual: Richard Todd, Registrar & Ruth Casper, Assistant Vice President of Student Financial Services Corrective Action: The University Financial Aid Office will work alongside the Registrar’s Office to identify and correct any enrollment reporting errors which may arise. Co...
Name of Responsible Individual: Richard Todd, Registrar & Ruth Casper, Assistant Vice President of Student Financial Services Corrective Action: The University Financial Aid Office will work alongside the Registrar’s Office to identify and correct any enrollment reporting errors which may arise. Corrections may include subsequent reporting to the Clearinghouse and/or manual reporting to NSLDS. Anticipated Completion Date: Ongoing
Finding 524341 (2024-002)
Significant Deficiency 2024
The College acknowledges that, while student status change information was being sent to the NSC, it did not have an appropriate process in place to regularly review and reconcile the data received by the NSLDS and information for 2 students was not properly remitted. A correction was made to the e...
The College acknowledges that, while student status change information was being sent to the NSC, it did not have an appropriate process in place to regularly review and reconcile the data received by the NSLDS and information for 2 students was not properly remitted. A correction was made to the existing reconciliation report so that all statuses remitted to the NSLDS are captured accurately and can be reconciled by the Registrar’s Office to the College’s enrollment records. Additionally, the College will adopt a practice of manually updating the NSC after receiving each student status change notification throughout the semester. The Planned Corrective Action will be implemented immediately.
Finding 524316 (2024-001)
Significant Deficiency 2024
FINDING 2024-001 Name of Responsible Individual: Daniel Arndt, Registrar Corrective Action: Management acknowledges the finding regarding the inaccurate reporting of student data elements under the Program-Level record on the NSLDS website. To address this issue, the University has implemented a cor...
FINDING 2024-001 Name of Responsible Individual: Daniel Arndt, Registrar Corrective Action: Management acknowledges the finding regarding the inaccurate reporting of student data elements under the Program-Level record on the NSLDS website. To address this issue, the University has implemented a corrective action plan that includes updating our reporting frequency and enhancing our data review processes: Updated Reporting Frequency: As of January 2025, the University now includes the non-compulsory terms, summer 1 and winter sessions, in its reporting. Previous institutional practice did not include reporting program level data for these terms given that said terms do not involve federal financial aid. This change ensures that all Program-Level data, regardless of federal financial aid involvement, is accurately reported. Secondary Check Process: Each month, the Compliance Officer will review a sample of 100 students from NSLDS to verify significant data elements, including program enrollment effective dates. After the initial review, the Compliance Officer will summarize the findings and share them with the Associate Registrar and Registrar for a secondary review. Any necessary edits will be made, followed by a review of an additional 25 students to ensure accuracy. We believe these corrective action steps are critical to ensuring accurate reporting and preventing this issue in the future. Anticipated Completion Date: January 31, 2025
2024-006 – Common Origination and Disbursement (COD) Reporting. Auditor Description of Condition and Effect. During our testing of COD reporting, we identified one of 40 disbursements was not reported to COD within 15 days of the disbursement date. A lack of timely reporting may prevent the College ...
2024-006 – Common Origination and Disbursement (COD) Reporting. Auditor Description of Condition and Effect. During our testing of COD reporting, we identified one of 40 disbursements was not reported to COD within 15 days of the disbursement date. A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Auditor Recommendation. We recommend that the College evaluate and enhance its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Corrective Action. I have a procedure in place to report graduates as soon as they are confirmed with academics. Responsible Party. Financial Aid Director, Jennifer Stimson. Anticipated Completion Date. January 2025.
2024-005 – Pell Grant Calculation. Auditor Description of Condition and Effect. One student out of the twenty five Pell grants tested was found to be under awarded based on the enrollment status and cost of attendance. As a result of this condition, the College was exposed to an increased risk that ...
2024-005 – Pell Grant Calculation. Auditor Description of Condition and Effect. One student out of the twenty five Pell grants tested was found to be under awarded based on the enrollment status and cost of attendance. As a result of this condition, the College was exposed to an increased risk that incorrect information would be used to determine students' Pell Grant award amounts. Auditor Recommendation. We recommend the College implement procedures to ensure the COA and EFC used to calculate each student's Pell Grant is updated for each academic year and reviewed by an independent official. Corrective Action. This is corrected on setup and noted to correct the COA. Responsible Party. Financial Aid Director, Jennifer Stimson. Anticipated Completion Date. March 2025 - next set up, it was corrected for 24/25 academic year in May 2024.
2024-004 – Fiscal Operations Report and Application to Participate (FISAP) Reporting. Auditor Description of Condition and Effect. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items identified in the compliance supplement as critica...
2024-004 – Fiscal Operations Report and Application to Participate (FISAP) Reporting. Auditor Description of Condition and Effect. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items identified in the compliance supplement as critical information. The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately reporting information. Auditor Recommendation. We recommend the College review their policies and procedures surrounding FISAP reporting. Corrective Action. Adjust notes on the procedure (or guidelines), laying out the complete steps of FISAP to ensure the data is accurate. Responsible Party. Financial Aid Director, Jennifer Stimson. Anticipated Completion Date. February 2025 - the next FISAP.
2024-003 – Timeliness of Status Change Reporting. Auditor Description of Condition and Effect. It was noted during our testing of 13 students with status changes, two instances of late reporting of status changes. Both of these instances were fall graduates whose status change was not reported withi...
2024-003 – Timeliness of Status Change Reporting. Auditor Description of Condition and Effect. It was noted during our testing of 13 students with status changes, two instances of late reporting of status changes. Both of these instances were fall graduates whose status change was not reported within the required timeframe. As a result of this condition, the NSLDS had incorrect records of the enrollment status of students. Auditor Recommendation. We recommend the College reviews the status change reporting requirements and implement procedures to ensure that the status changes are being reported to the NSLDS in a timely manner. Corrective Action. To view graduated student's as soon as they have been processed. Responsible Party. Financial Aid Director, Jennifer Stimson. Anticipated Completion Date. November 2024.
2024-002 – Return of Title IV (R2T4) Calculation. Auditor Description of Condition and Effect. During our testing of six students with Return of Title IV amounts, we noted that the College did not exclude the correct amount of days for scheduled breaks of five days or more in both the fall 2023 and ...
2024-002 – Return of Title IV (R2T4) Calculation. Auditor Description of Condition and Effect. During our testing of six students with Return of Title IV amounts, we noted that the College did not exclude the correct amount of days for scheduled breaks of five days or more in both the fall 2023 and spring 2024 terms, resulting in the incorrect Return of Title IV calculation for all students tested. As a result of this condition, the students' return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount. Auditor Recommendation. We recommend the College review the Return of Title IV requirements and implement procedures to ensure the Return of Title IV calculations are using the correct amount of term days and are completed accurately. Corrective Action. This has been noted in setup notes, so the number of days are correct going forward. Responsible Party. Financial Aid Director, Jennifer Stimson. Anticipated Completion Date. November 2024.
Corrective Action Plan from College: This is submitted to Derrick Everhart, Director of Financial Aid, by the College Registrar Brooke Millsaps. In order to correct the need to have a monitoring mechanism in place, the College has taken the following actions: ● Warren Wilson College convened a group...
Corrective Action Plan from College: This is submitted to Derrick Everhart, Director of Financial Aid, by the College Registrar Brooke Millsaps. In order to correct the need to have a monitoring mechanism in place, the College has taken the following actions: ● Warren Wilson College convened a group of stakeholders to review our exit and withdrawal procedures. This group included representatives from the following offices: Financial Aid, Registrar, tudent Accounts, Student Engagement, Office of the Provost. ● The group revised our procedures when a student indicates they want to leave the College. These revised procedures include the following: 1. Developed a specific chart to determine the classification of the student, the time of year of the action, and the circumstances of the action: See Corrective Action Plan for chart / table. 2. Removed a student's ability to complete the exit form once classes started in order to prevent an erroneous student exit 3. Implemented an Administrative Exit - census verification process . This allows the college the opportunity to verify through roster verification, work participation, and residential status if a student should be administratively exited. 4. As a result of this revised institutional procedure, the Office of the Registrar reviewed and revised its procedures regarding exits and withdrawals to ensure that we are documenting accurate information in the appropriate locations within Jenzabar. This will ensure that when we report data to the National Student Clearinghouse, the associated exits and withdrawal dates are in alignment. Management Response : The Director of Financial Aid concurs with this finding and noted while the College was out of compliance with the reporting timeframe, the College did make a substantial effort to complete the requirements and follow up with NSLDS and NSC to correct the students enrollment. Contact College personnel for corrective action. Derrick Everhart, Director of Financial Aid deverhart@warren-wilson.edu Brooke Milsaps, College Registrar bmillsaps@warren-wilson.edu
Finding Summary: U.S. Department of Education Student Financial Aid Cluster (FAL # 84.268, 84.063) Eligibility Significant Deficiency in Internal Control over Compliance Responsible Individuals: Alicia Smith, Director of Financial Aid Corrective Action Plan: The process has been adjusted to ensure m...
Finding Summary: U.S. Department of Education Student Financial Aid Cluster (FAL # 84.268, 84.063) Eligibility Significant Deficiency in Internal Control over Compliance Responsible Individuals: Alicia Smith, Director of Financial Aid Corrective Action Plan: The process has been adjusted to ensure manual calculations are done independently by two different people. Anticipated Completion Date: July 1, 2025
Finding Summary: U.S. Department of Education Student Financial Aid Cluster (FFAL #84.268 and #84.063) Special Test: Return of Funds Significant Deficiency in Internal Control over Compliance Responsible Individuals: Alicia Smith, Director of Financial Aid Corrective Action Plan: The process has bee...
Finding Summary: U.S. Department of Education Student Financial Aid Cluster (FFAL #84.268 and #84.063) Special Test: Return of Funds Significant Deficiency in Internal Control over Compliance Responsible Individuals: Alicia Smith, Director of Financial Aid Corrective Action Plan: The process has been adjusted to ensure manual calculations are done independently by two different people. Anticipated Completion Date: July 1, 2025
Documentation of Review Recommendation: We recommend the University reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: F...
Documentation of Review Recommendation: We recommend the University reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid will send a reconciliation to the Controller by the 10th business day. The controller will review and approve by the 15th business day. Name of the contact person responsible for corrective action: Scott Roelke, Director of Financial Aid Planned completion date for corrective action plan: 2/4/2025
Return of Title IV Funds Recommendation: We recommend the University review the R2T4 calculations and the term dates used. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university will manually review student...
Return of Title IV Funds Recommendation: We recommend the University review the R2T4 calculations and the term dates used. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university will manually review student registration begin and end dates for all students where withdrawal records indicate a R2T4 calculation may be required. This review will ensure appropriate dates are used for determining the need for a R2T4 calculation, and for student records requiring a R2T4 calculation, that the calculation is completed using the correct number of days. Name of the contact person responsible for corrective action: Scott Roelke, Director of Financial Aid Planned completion date for corrective action plan: In place as of February 14, 2025.
View Audit 343204 Questioned Costs: $1
Perkins Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to findin...
Perkins Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the audit finding where some MPNs are missing. We are unable to correct the past but moving forward, the new ones are being retained. Name of the contact person responsible for corrective action: Jane Garner, CFO Planned completion date for corrective action plan: Already in place
National Student Loan Data System (NSLDS) Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”. Explanation of disagreement with audit finding: There is no disagr...
National Student Loan Data System (NSLDS) Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Although the Colleague data is correct, the logic in Colleague used to send the files to the NSC is excluding records when the student is not registered for classes in the month an action such as graduation or withdrawal occurs. In that situation the NSC is inserting default dates onto the record based on the last date of their classes in the prior term. We are working with our IT team & Ellucian on an approach to update that logic. In the meantime, we will implement a reporting solution to allow manual correction of these issues. Name of the contact person responsible for corrective action: Kris Ragozzino, Registrar Planned completion date for corrective action plan: Already in place.
Finding 523967 (2024-001)
Significant Deficiency 2024
Finding 2024-001 Condition Condition: The change in student status for 25 of the 25 students tested was not reported to the National Student Loan Data Systems (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, these students were ultimately reported to the N...
Finding 2024-001 Condition Condition: The change in student status for 25 of the 25 students tested was not reported to the National Student Loan Data Systems (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, these students were ultimately reported to the NSLDS. Corrective Action Plan The Director of Student Financial Services and the Registrar resolved the issue that caused delayed enrollment changes being submitted to NSLDS due to turnover. The Office of the Registrar identified the errors in the National Student Clearinghouse reporting. They worked internally with our IT department to pinpoint the errors resulting in delays in submission to the National Student Loan Database Systems (NSLDS) via the National Student Clearinghouse. The Office of the Registrar submitted overdue files to the National Clearinghouse in conjunction with the Senior Director of Information Technology to ensure all technical requirements are met. These updates and alignments should bring late reporting to zero. As of January 2025, all prior term file submissions have been submitted to the National Student Clearinghouse. Name of Contact Person Responsible for Corrective Action: Elizabeth Brentzel Anticipated Completion Date: Winter 2025
Finding 2024-004 Student Financial Aid Cluster, CFDA # 84.063, 84.268 Condition: The College did not report the actual disbursement date that students receive the Direct Loan and/or Pell Funds to the COD system. Corrective Action Plan: ...
Finding 2024-004 Student Financial Aid Cluster, CFDA # 84.063, 84.268 Condition: The College did not report the actual disbursement date that students receive the Direct Loan and/or Pell Funds to the COD system. Corrective Action Plan: Objective: To ensure the Financial Aid office reports the actual disbursement date the student receives the Direct Loan and/or Pell funds to the COD system. Corrective Actions: 1. Establish a Standard Operating Procedure (SOP) for reporting disbursement dates 2. Implement an automated system for disbursement reporting 3. Training for Financial Aid and Accounting staff 4. Coordination between relevant departments 5. Verification and reconciliation process 6. Review and monitor data submissions 7. Establish a process for correcting disbursement errors 8. Ongoing monitoring and follow-up Monitoring and Follow-Up: The Financial Aid Office will be responsible for ensuring the implementation of this corrective action plan and will provide monthly updates to senior management. Person(s) Responsible for Corrective Action Plan: Jamieta Hoskins, Director of Financial Aid Anticipated Completion Date for Corrective Action Plan: March 31, 2025
Finding 2024-002 Student Financial Aid Cluster, Assistance Listing # 84.063, 84.268 Condition: The College did not send changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Corrective Action ...
Finding 2024-002 Student Financial Aid Cluster, Assistance Listing # 84.063, 84.268 Condition: The College did not send changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Corrective Action Plan: Objective: To ensure the timely reporting of changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled, to the National Student Loan Data Center (NSLDS) within 60 days of the change. Corrective Actions: 1. Review and update internal policies and procedures 2. Training and education for relevant staff 3. Implement a tracking and monitoring system 4. Conduct regular audits and monitoring 5. Collaborate with NSLDS for support and guidance Monitoring and Follow-Up: • The College’s Financial Aid Office will track the implementation of this Corrective Action Plan and provide monthly progress updates to senior management. • The College will conduct periodic reviews and evaluations to ensure that the plan’s objectives are being met and that the institution remains in full compliance with the Department of Education’s reporting requirements. Person(s) Responsible for Corrective Action Plan: Jamieta Hoskins, Director of Financial Aid Anticipated Completion Date for Corrective Action Plan: February 28, 2025
Management concurs with the finding and the auditor's recommendation to make timely calculations to determine if a refund of Title IV funds is required when a student withdraws. The return of Title IV funds to the U.S. Department were made, but not within the required 45 days. The Seminary has rev...
Management concurs with the finding and the auditor's recommendation to make timely calculations to determine if a refund of Title IV funds is required when a student withdraws. The return of Title IV funds to the U.S. Department were made, but not within the required 45 days. The Seminary has reviewed our procedures to prevent future late returns of Title IV funds. The return of Title IV funds was resolved as June 30, 2024. The Seminary is continuing to review our processes for the return of Title IV funds. We have established procedures to notify the person(s) responsible for calculating if a reunds needs to be made and another person to oversee the process, review the calculation and make sure the funds are returned in a timely manner.
View Audit 343080 Questioned Costs: $1
To address the discrepancies, TVCC has taken the following actions: 1. Properly updated the enrollment status of each of the three (3) identified students in the National Student Clearinghouse (NSC) via NSC’s “Student Lookup” tool. 2. Identified and implemented a mechanism to correct the enrollment...
To address the discrepancies, TVCC has taken the following actions: 1. Properly updated the enrollment status of each of the three (3) identified students in the National Student Clearinghouse (NSC) via NSC’s “Student Lookup” tool. 2. Identified and implemented a mechanism to correct the enrollment status issues caused by CPCC issuance. 3. Assigned a dedicated NSC staff member to process enrollment report submissions and resolve errors. 4. The Registrar’s Office and Financial Aid Office , in collaboration with the Enterprise Systems Support Analyst, are implementing an internal audit tool to better screen enrollment and graduate reports before submission to NSC.
Management agrees with the finding. The College has controls in place to ensure proper and timely reporting to the third-party service provider. The exceptions included above reflected incorrect enrollment statuses on the Banner report due to unofficial withdrawals by the students. The College is c...
Management agrees with the finding. The College has controls in place to ensure proper and timely reporting to the third-party service provider. The exceptions included above reflected incorrect enrollment statuses on the Banner report due to unofficial withdrawals by the students. The College is currently working with their third-party service provider and the Alabama Community College System (ACCS) to ensure the enrollment status of the students is properly reflected on the Banner reports moving forward. We are currently working with ACCS and the National Student Clearinghouse (NSC) to ensure the statuses of the students are reported correctly. 1)The end of term enrollment status reporting process will be ran after the unofficial withdrawals have been completed. 2) The Banner report will be reviewed for accuracy to ensure the unofficially withdrawn students have the correct enrollment status. 3)All Banner reports sent to NSC will be kept on the shared drive to document timely reporting along with the dates reported. 4) All NSC error reports will be downloaded to document the timely review of errors.
The College will have the Director of Financial Aid to send the post-withdrawal letter the same day as performing the return of funds calculations which will be well within the 45 day requirement. If a post-withdrawal letter is to be sent, it will be recorded and logged on the same spreadsheet the F...
The College will have the Director of Financial Aid to send the post-withdrawal letter the same day as performing the return of funds calculations which will be well within the 45 day requirement. If a post-withdrawal letter is to be sent, it will be recorded and logged on the same spreadsheet the Financial Aid Office tracks withdrawals. Completion date: 2/15/2025. Responsible staff: Crystal Hamilton, Director of Financial Aid
The College has reviewed it’s policies and procedures related to return of funds calculations. When a student wants to withdraw from the College, the student will complete an online withdrawal form. Once the form is completed, an electronic copy of the form is sent to several offices, Financial Aid ...
The College has reviewed it’s policies and procedures related to return of funds calculations. When a student wants to withdraw from the College, the student will complete an online withdrawal form. Once the form is completed, an electronic copy of the form is sent to several offices, Financial Aid being included. The Financial Aid Office will use the date on the electronic withdraw form in the Return of Title IV calculation. Completion date: 2/15/2025. Responsible staff: Crystal Hamilton, Director of Financial Aid
View Audit 342864 Questioned Costs: $1
The College is not an attendance taking school and will not be using last date attended, but the College has implemented procedure to use the last date of an academic activity as standard for a non-attendance taking school. At the end of each semester, the College has put a procedure in place to rev...
The College is not an attendance taking school and will not be using last date attended, but the College has implemented procedure to use the last date of an academic activity as standard for a non-attendance taking school. At the end of each semester, the College has put a procedure in place to review all grades within 7 business days of final grades being reported. Once reviewed, the Director of Financial Aid will send an email to all faculty for the student to request that last date of an academic activity for on-ground students. For online students, the Director of Online Learning will provide the last date an academic activity recorded in the online platform. Once the last date of academic activity has been provided to the Financial Aid Office, that date will be used in the return of funds calculation. The College will process all return of funds calculations before the standard 45 day timeframe. Completion date: 2/15/2025. Responsible staff: Crystal Hamilton, Director of Financial Aid
View Audit 342864 Questioned Costs: $1
The Registrar’s Office will review the enrollment roster before the information is uploaded to National Student Clearinghouse and will do a second a review of the report that the National Student Clearinghouse will populate upon processing the enrollment roster. The Registrar’s Office will send enro...
The Registrar’s Office will review the enrollment roster before the information is uploaded to National Student Clearinghouse and will do a second a review of the report that the National Student Clearinghouse will populate upon processing the enrollment roster. The Registrar’s Office will send enrollment rosters every 30 days to the National Student Clearinghouse (NSC). Graduate roster will be sent to the National Student Clearinghouse within 60 days of degree completion. National Student Clearinghouse will then send the information to NSLDS for the information in NSLDS to be updated. Completion date 2/15/2025. Responsible staff: Margaret Smith, Registrar
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