Corrective Action Plans

Finding 1220601 (2025-001)

Material Weakness 2025

St. Agnes Senior Citizen Housing Development Fund Company, Inc.

NY

HUD Housing Programs Student Financial Aid Eligibility

Corrective Action Plan: The annual recertifications were not completed on time due to difficulty obtaining the required tenant information. Stanan will start the process earlier in the year to collect the documentation needed. Stanan’s occupancy specialist and supervisor will closely monitor the tim...

Corrective Action Plan: The annual recertifications were not completed on time due to difficulty obtaining the required tenant information. Stanan will start the process earlier in the year to collect the documentation needed. Stanan’s occupancy specialist and supervisor will closely monitor the timing and progress of all tenant annual recertifications to avoid untimely filings in the future. Anticipated Completion Date: The implementation of training and procedures is expected to be completed by September 30, 2026.

View Audit 405449

Finding 1220598 (2025-002)

Material Weakness 2025

George Link, Jr. Apartments Housing Development Fund Company, Inc.

NY

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

Corrective Action Plan: The return of tenant security deposits were not completed on time due to staff turnover. Stanan’s occupancy specialist and supervisor will closely monitor the timing of the return of security deposits. Anticipated Completion Date: The implementation of training and procedures...

Corrective Action Plan: The return of tenant security deposits were not completed on time due to staff turnover. Stanan’s occupancy specialist and supervisor will closely monitor the timing of the return of security deposits. Anticipated Completion Date: The implementation of training and procedures is expected to be completed by September 30, 2026.

View Audit 405444

Finding 1220597 (2025-001)

Material Weakness 2025

George Link, Jr. Apartments Housing Development Fund Company, Inc.

NY

HUD Housing Programs Student Financial Aid Eligibility

Corrective Action Plan: The annual recertifications were not completed on time due to difficulty obtaining the required tenant information. Stanan will start the process earlier in the year to collect the documentation needed. Stanan’s occupancy specialist and supervisor will closely monitor the tim...

Corrective Action Plan: The annual recertifications were not completed on time due to difficulty obtaining the required tenant information. Stanan will start the process earlier in the year to collect the documentation needed. Stanan’s occupancy specialist and supervisor will closely monitor the timing and progress of all tenant annual recertifications to avoid untimely filings in the future. Anticipated Completion Date: The implementation of training and procedures is expected to be completed by September 30, 2026.

View Audit 405444

Finding 1220595 (2025-001)

Material Weakness 2025

Bishop Gerald J. Ryan Housing Development Fund Company, Inc.

NY

HUD Housing Programs Student Financial Aid Eligibility

Corrective Action Plan: The annual recertifications were not completed on time due to difficulty obtaining the required tenant information. Stanan will start the process earlier in the year to collect the documentation needed. Stanan’s occupancy specialist and supervisor will closely monitor the tim...

Corrective Action Plan: The annual recertifications were not completed on time due to difficulty obtaining the required tenant information. Stanan will start the process earlier in the year to collect the documentation needed. Stanan’s occupancy specialist and supervisor will closely monitor the timing and progress of all tenant annual recertifications to avoid untimely filings in the future. Anticipated Completion Date: The implementation of training and procedures is expected to be completed by September 30, 2026.

View Audit 405442

Finding 1220202 (2025-022)

Material Weakness 2025

Government of the District of Columbia

DC

Questioned Costs Special Tests & Provisions Student Financial Aid § 200.303

The Child and Family Services Agency (CFSA) concurs with the finding. CFSA has instituted a point-of-payment invoice validation and cost determination process that will allow the Agency to retire the quarterly expenditure reporting process in its entirety. Providers submit invoices that align with t...

The Child and Family Services Agency (CFSA) concurs with the finding. CFSA has instituted a point-of-payment invoice validation and cost determination process that will allow the Agency to retire the quarterly expenditure reporting process in its entirety. Providers submit invoices that align with their contract schedules and they self-report on a schedule-oriented tool. The CFSA team reviews, validates, and approves each and every invoice. The tool tracks invoiced cost for the entire fiscal year such that by year’s end there is a verified, validated catalogue of reported costs that are used to derive the family-based rate that drive the adjustment claims for these special tests and provisions.

View Audit 405318

Finding 1220201 (2025-021)

Material Weakness 2025

Government of the District of Columbia

DC

Questioned Costs Student Financial Aid Eligibility § 200.303

The Child and Family Services Agency (CFSA) concurs with the finding. The June 2025 implementation of STAAND, CFSA’s new system, included safeguards to mitigate the generation of claims for federal reimbursement for payments made to any provider for which there is a critical licensure issue.

View Audit 405318

Finding 1220192 (2025-013)

Material Weakness 2025

Government of the District of Columbia

DC

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

The University of the District of Columbia (UDC) agrees with the conditions and recommendations of this finding. Management action plan includes the following steps: • The Office of the Registrar will continue to use National Student Clearinghouse third party reporting tool to report enrollment data...

The University of the District of Columbia (UDC) agrees with the conditions and recommendations of this finding. Management action plan includes the following steps: • The Office of the Registrar will continue to use National Student Clearinghouse third party reporting tool to report enrollment data to NSLDS. • The Office of the Registrar continues to utilize the "Submission schedule tool" to keep us compliant with the timeframe required for submission of the reports. • Students who have been reported during the first week of courses as "Never Attended - NA" will be dropped from their courses for the term no more than 1 week after the end of attendance verification. • The Enrollment Time Status (Full Time, Part Time, etc.) for student who are enrolled in Summer courses will be updated effective immediately.

View Audit 405318

Finding 1220188 (2025-012)

Material Weakness 2025

Government of the District of Columbia

DC

Internal Control / Segregation of Duties Questioned Costs Special Tests & Provisions § 200.303

The University of the District of Columbia (UDC) agrees with the conditions and recommendations of this finding. Management action plan includes the following steps: The Office of Financial Aid is implementing enhanced controls to strengthen the accuracy and timeliness of its Return of Title IV Fund...

The University of the District of Columbia (UDC) agrees with the conditions and recommendations of this finding. Management action plan includes the following steps: The Office of Financial Aid is implementing enhanced controls to strengthen the accuracy and timeliness of its Return of Title IV Funds (R2T4) processes. Moving forward, all official and unofficial R2T4 calculations will be subject to more comprehensive review, replacing the prior practice of reviewing a limited sample. To further support compliance and coordination, automated email notifications will be issued to designated staff responsible for both loan and Pell Grant reporting whenever an R2T4 is processed. This will ensure timely awareness and appropriate action by all relevant parties. In addition, staff calendars will be updated to include critical regulatory deadlines associated with the return of Title IV funds. These calendar controls are intended to reinforce adherence to federal requirements and promote consistency across all cases. These measures are designed to improve oversight, enhance internal controls, and ensure full compliance with federal Title IV regulations. The Office of Financial Aid acknowledges that elements of these controls had been previously identified and implemented; however, these processes will be further strengthened, formalized, and consistently applied to ensure full compliance with federal Title IV regulations.

View Audit 405318

Finding 1220184 (2025-011)

Material Weakness 2025

Government of the District of Columbia

DC

Internal Control / Segregation of Duties Questioned Costs Special Tests & Provisions § 200.303

The University of the District of Columbia (UDC) agrees with the conditions and recommendations of this finding. Management action plan includes the following steps: • The Bursar or designee shall run a report daily of all Title IV disbursements that occurred on the prior business day. • The Bursar ...

The University of the District of Columbia (UDC) agrees with the conditions and recommendations of this finding. Management action plan includes the following steps: • The Bursar or designee shall run a report daily of all Title IV disbursements that occurred on the prior business day. • The Bursar or designee will run a report for Title IV funding awarded the previous day for the terms shown on the disbursement report above and select students who had a Title IV disbursement based upon the report above. • The students with the disbursements shall be reviewed in addition to any other student shown having a Title IV Credit balance to determine if a non-refunded Title IV credit balance exist. • Where a non-refunded Title IV credit balance exist, the student shall be included in the list of refunds named Refund Review Report dd/mm/yyyy to be processed following the institution refund process for Title IV Credit Balances. • At the end of the day, the Bursar or designee shall generate a report showing the refunds entered in the system for that day and confirm all previously identified Title IV refunds credit balance refunds were completed and attach said report to the refund review report and save in a designated folder. • The Bursar or designee will complete the batch release process daily to allow refund entered on student records to be transmitted to AP following institutional process. • On the AP check run date, the Bursar or designee shall review the check run notification from AP to confirm all refunds entered in the system since last check run date have been processed successfully. • We will conduct collective training with staff involved in student credit processing as it pertains to Department of Education regulations. Additionally, we will train Staff to ensure understanding of the Corrective Action Plan (CAP) to be taken.

View Audit 405318

Finding 1220180 (2025-010)

Material Weakness 2025

Government of the District of Columbia

DC

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

The University of the District of Columbia (UDC) agrees with the conditions and recommendations of this finding. Management action plan includes the following steps: The Office of Financial Aid has recognized irregularities in the student disbursement notification process. The office currently utili...

The University of the District of Columbia (UDC) agrees with the conditions and recommendations of this finding. Management action plan includes the following steps: The Office of Financial Aid has recognized irregularities in the student disbursement notification process. The office currently utilizes Banner Communication Management (BCM) as the primary system for delivering required notifications to students. While this system has historically functioned effectively, recent observations indicated inconsistencies that impacted the timely delivery of certain required notices. In response, the office will initiate enhancements to its notification procedures. Specifically, we will implement a supplementary notification process that will include the use of our new platform, Salesforce. The use of Salesforce should help to provide a reliable communication system for our messages. This dual process approach is intended to strengthen reliability and provide redundancy in the delivery of required communications. These improvements are designed to ensure that all disbursement notifications are transmitted within required timeframes, in full compliance with federal Title IV regulations.

View Audit 405318

Finding 1220176 (2025-009)

Material Weakness 2025

Government of the District of Columbia

DC

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

The University of the District of Columbia (UDC) agrees with the conditions and recommendations of this finding. The Office of Financial Aid experienced staff turnover, which impacted the timeliness of reporting submissions to the Common Origination and Disbursement (COD) system. This challenge was ...

The University of the District of Columbia (UDC) agrees with the conditions and recommendations of this finding. The Office of Financial Aid experienced staff turnover, which impacted the timeliness of reporting submissions to the Common Origination and Disbursement (COD) system. This challenge was further compounded by the need to train and cross-train staff to ensure continuity in reporting responsibilities. To address this issue, the office has identified and trained two staff members who are capable of originating and submitting enrollment reporting to COD. Additionally, we have implemented enhanced internal controls, including weekly reporting processes, to ensure compliance with all required deadlines. These measures are designed to ensure that records are submitted within the mandated 15-day timeframe.

View Audit 405318

Finding 1218682 (2025-007)

Material Weakness 2025

State of Michigan

MI

Internal Control / Segregation of Duties Questioned Costs Student Financial Aid

Finding 2025-007 MiSACWIS Security Management and Access Controls Management Views MDHHS agrees with the finding. Planned Corrective Action For part a., MDHHS currently has a process in place to review the user narrative describing the incompatible role exceptions within the DSA Michigan Statewide A...

Finding 2025-007 MiSACWIS Security Management and Access Controls Management Views MDHHS agrees with the finding. Planned Corrective Action For part a., MDHHS currently has a process in place to review the user narrative describing the incompatible role exceptions within the DSA Michigan Statewide Automated Child Welfare Information System (MiSACWIS) request as part of the approval process. Also, MDHHS added an incompatible role form in the DSA MiSACWIS request with automated routing for appropriate approval on November 11, 2025. In addition, MDHHS provides ongoing education during the quarterly LOSC webinars, where guidance is shared with the LOSCs on security management and access control topics, such as the correct procedures for processing system access requests. For part b., during April 2025, MDHHS updated the renewal processing start date to 15 days earlier to ensure renewal requests are reviewed prior to the annual recertification date. Anticipated Completion Date Completed Responsible Individual(s) Tim Kwast, MDHHS Alana Lowe, MDHHS

View Audit 404775

Finding 1218646 (2025-044)

Material Weakness 2025

State of Michigan

MI

Allowable Costs / Cost Principles Questioned Costs Student Financial Aid § 200.516

Finding 2025-044 Temporary Assistance for Needy Families, ALN 93.558 - Inappropriate TANF-Funded Emergency Foster Care Assistance Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS redetermined the Foster Care Title IV-E (Title IV-E) eligibility after the birth certifica...

Finding 2025-044 Temporary Assistance for Needy Families, ALN 93.558 - Inappropriate TANF-Funded Emergency Foster Care Assistance Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS redetermined the Foster Care Title IV-E (Title IV-E) eligibility after the birth certificate was received and the youth was determined to be Title IV-E eligible. MDHHS has already reclassified the funds to the appropriate funding source, allowing the department to claim Title IV-E for the eligible placement, and repaying any TANF overpayments. Reconciliations between different fund sources, or recoupments for overpayments, will be created within 30 calendar days of receipt of supporting documentation and approved timely by management. All recoupment and reconciliation records will be approved by management no later than September 30 each fiscal year to ensure compliance with year-end requirements. Anticipated Completion Date September 30, 2026 Responsible Individual(s) Nancy Berger, MDHHS

View Audit 404775

Finding 1218314 (2025-002)

Material Weakness 2025

American Academy McAllister Institute of Funeral Service, Inc.

NY

Student Financial Aid Questioned Costs Special Tests & Provisions

In May of 2026, the Institute amended its procedures to (1) require the printing of a schedule of student balances after application of Federal Pell Grant and Loan receipts and (2) for all students with a credit balance within 12 days of the Pell receipt indicating the check number and date of the r...

In May of 2026, the Institute amended its procedures to (1) require the printing of a schedule of student balances after application of Federal Pell Grant and Loan receipts and (2) for all students with a credit balance within 12 days of the Pell receipt indicating the check number and date of the refund to the student on this schedule. This schedule is then to be reviewed for adherence to the required 14-day refund requirement under the Pell program by another staff member.

View Audit 404554

Finding 1218313 (2025-001)

Material Weakness 2025

American Academy McAllister Institute of Funeral Service, Inc.

NY

Student Financial Aid Questioned Costs Special Tests & Provisions

As reported in the Institutes fiscal 2024 Corrective Action Plan, in May 2025, the Institute revised its current procedures to include having an employee independent from the exit conference process review that any student not enrolled in a new semester or that is enrolled at less than half time sta...

As reported in the Institutes fiscal 2024 Corrective Action Plan, in May 2025, the Institute revised its current procedures to include having an employee independent from the exit conference process review that any student not enrolled in a new semester or that is enrolled at less than half time status has received proper exit conferencing and that exit conferencing has been properly documented. Two of the findings in the current fiscal 2025 occurred prior to the May revision by the Institute of its procedures. The third finding occurred during a period that the independent party performing the review function was on leave due to a death in the family. The Institute recognizes the importance of ensuring that exit conferences are performed timely and properly documented. Management has met with its staff involved in this process to emphasize its importance. Additionally, an additional staff member has been assigned to perform the review procedures if the staff member responsible is not available to timely perform the procedures.

View Audit 404554

Finding 1218147 (2025-006)

Material Weakness 2025

Columbia Gorge Community College

OR

Questioned Costs Procurement, Suspension & Debarment Student Financial Aid § 200.303

Recommendation: We recommend that the college review its processes and internal controls related to SAP and ensure procedures are in place to ensure students who are not meeting SAP requirements are properly identified and disbursed aid in accordance with the institution’s SAP policy. Explanation of...

Recommendation: We recommend that the college review its processes and internal controls related to SAP and ensure procedures are in place to ensure students who are not meeting SAP requirements are properly identified and disbursed aid in accordance with the institution’s SAP policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since December 2025, the College has worked with the SIS Managed Services team (Anthology now Ellucian) to update its SAP policy and ensure compliance with federal regulations. The new SAP policy was fully implemented effective during the Winter 2026 term. As an internal control, at the end of each term when SAP is evaluated, the results are pre-screened by the Coordinator of Financial Aid with oversight from the Director of Financial Aid to ensure accuracy before results are posted live in the system. Additionally, the College has clarified its understanding of Anthology’s treatment of students who are newly enrolled at the College or who have changed into a different program version. These students are designated with a not-calculated SAP which represents a blank or null status until the conclusion of the term when the students receive a passing or failing grade and can be evaluated by the SAP standards. Steps also have been taken to ensure that prior enrollments are linked to ensure integrity of the application of SAP standards based on the cumulative pace, GPA and maximum timeframe. As a further measure to ensure the integrity of awarding Title IV funds only to eligible students, the College has placed students with prior ineligible SAP statuses in a hold group within the SIS and identified these students as not meeting Disbursement Approval Criteria (DAC) thus causing any attempt to disburse funds to them to fail. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

View Audit 404328

Finding 1218146 (2025-005)

Material Weakness 2025

Columbia Gorge Community College

OR

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

Recommendation: We recommend the College changes its process and controls to ensure exit counseling emails are sent to graduate/withdrawn students throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding...

Recommendation: We recommend the College changes its process and controls to ensure exit counseling emails are sent to graduate/withdrawn students throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since August 2025, the College has taken steps in conjunction with its SIS Managed Services team (Anthology) to establish an automated process to notify graduate/withdrawn students to complete the Exit Counseling requirement. Since then the Director of Financial Aid has been spot-checking the notifications to ensure that the exit counseling notification is being triggered for withdrawn students. Going forward, the Financial Aid Office will use the Task Function in Anthology to confirm that the notification has been sent and close the task which will be timestamped with the name of the reviewer. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

View Audit 404328

Finding 1218145 (2025-004)

Material Weakness 2025

Columbia Gorge Community College

OR

Matching / Level of Effort / Earmarking Questioned Costs Student Financial Aid § 200.303

Recommendation: We recommend the college review its process and procedures for R2T4 calculations to ensure they are in line with Dept. of Education requirements. We also recommend the college maintain evidence of the formal review process that ensures Return of Title IV calculations are being perfor...

Recommendation: We recommend the college review its process and procedures for R2T4 calculations to ensure they are in line with Dept. of Education requirements. We also recommend the college maintain evidence of the formal review process that ensures Return of Title IV calculations are being performed timely and correctly to minimize the likelihood that errors may go undetected and not corrected in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will ensure that all Financial Aid policies and procedures are up-to-date; reviewed annually; and revised, as needed. Documentation will also be made for any procedures that are currently being performed by their third-party-servicer, Global including Return to Title IV (R2T4) calculations. As an internal control, the Financial Aid Office will retain records of the Return to Title IV calculations performed by Global; sign-off on the appropriate reports with the date reviewed; include the initials of the Coordinator of Financial Aid and co-signed by the Director of Financial Aid. The Coordinator of Financial Aid will notify Global of funds to be returned by the institution and/or student by completing the established process (GARP) to ensure that the funds are returned to the Department of Education within 45 days of the Date of Determination. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

View Audit 404328

Finding 1218144 (2025-003)

Material Weakness 2025

Columbia Gorge Community College

OR

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

Recommendation: We recommend the College review internal control reports and implement review controls for work performed by third-party servicers. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Currently, CGCC re...

Recommendation: We recommend the College review internal control reports and implement review controls for work performed by third-party servicers. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Currently, CGCC reviews several weekly reports from its third-party servicer, Global Financial Aid Services which indicates the actions which could not be completed by Global due to missing information, etc. These reports are discussed during the weekly call between Global and CGCC at which time steps are taken to resolve outstanding issues. CGCC also has access to other Financial Aid (FA) Reports in the Global Administration portal including verification, resolution of C-Flags and Unusual/Special Circumstances reviews which are conducted by Global. Going forward, the Financial Aid Office will review these reports monthly to ensure that the students are awarded and their funds disbursed in a timely fashion. As an internal control, documentation of the review of the FA reports will be retained, signed and dated by the Coordinator of Financial Aid and co-signed by the Director of Financial Aid. To further ensure integrity in the administration and awarding of Title IV funds, CGCC will annually request an SSAE 18 Report from Global in October of each year and subsequently, where applicable, a Bridge Letter to cover the intervening period between reports. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

View Audit 404328

Finding 1218143 (2025-001)

Material Weakness 2025

Columbia Gorge Community College

OR

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

Recommendation: We recommend the college review current processes and procedures for NSLDS enrollment reporting and retain evidence of an internal control that ensures timely and accurate reporting being performed. Explanation of disagreement with audit finding: There is no disagreement with the aud...

Recommendation: We recommend the college review current processes and procedures for NSLDS enrollment reporting and retain evidence of an internal control that ensures timely and accurate reporting being performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the past year, the College (CGCC) has worked vigorously to bring NSLDS enrollment reporting up-to-date. The College currently reports enrollment data to NSLDS through the National Student Clearinghouse. The Registrar annually establishes the Clearinghouse reporting schedule based on CGCC’s quarter system, including term start, midterm, and end dates. The schedule is posted in the Clearinghouse system, and Clearinghouse sends email reminders before scheduled reporting dates. The Registrar completes the scheduled reporting process, reviews posting results and error reports when received, and resolves any identified errors promptly to allow the enrollment file to be processed and reported. Going forward, the internal control will be to add secondary review by providing the retained report to the Vice President of Student Services. The report will include the date reviewed/submitted and the Registrar’s initials, and the Vice President will also initial the report as evidence of review. This provides documentation of completion and accountability to help ensure enrollment reporting is completed in a timely fashion. Name(s) of the contact person(s) responsible for corrective action: Catherine Graham. Planned completion date for corrective action plan: June 30, 2027.

View Audit 404328

Finding 1218138 (2025-002)

Material Weakness 2025

Columbia Gorge Community College

OR

Internal Control / Segregation of Duties Questioned Costs Student Financial Aid § 200.303

Recommendation: We recommend the college review the requirements and implement an internal process and control to specifically monitor the outstanding Title IV funded checks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to ...

Recommendation: We recommend the college review the requirements and implement an internal process and control to specifically monitor the outstanding Title IV funded checks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: On a monthly basis, as part of the bank reconciliation process, the Business Office generates a report of outstanding student refund checks and reviews it for uncashed items. Uncashed Title IV checks are recorded on a tracking log noting check number, issue date, and amount. When a check remains uncashed for 120 days, the Business Office contacts the student to confirm receipt or determine whether a reissue is needed, and the outreach is documented on the log. The monthly review and log are signed and dated by the preparer; co-signed by the Vice President of Administrative Services, and documentation is retained including months in which no exceptions are noted. At the conclusion of the monthly review process, an email with subject line: Uncashed Refund Checks is forwarded to the Financial Aid Office which includes a spreadsheet listing the students with uncashed refund checks or a note that there were no records for that particular month. Any Title IV check that remains uncashed is canceled by the Business Office. Within 5 - 7 business days of receiving the notification from the Business Office, the Financial Aid Office will notify the third-party servicer, Global Financial Aid Services (herein after referred to as Global) through their established reporting mechanism (GARP) to ensure the funds are returned to the Department of Education no later than 240 days after the date of issuance, as required by 34 CFR 668.164(h). Name(s) of the contact person(s) responsible for corrective action: Sam Draper and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

View Audit 404328

Finding 1218112 (2025-003)

Material Weakness 2025

Chestnut Hill College

PA

Student Financial Aid

Finding 2025-003: Gramm-Leach-Bliley Act (GLBA) Significant Deficiency in Internal Control over Compliance / Other Matters Views of Responsible Officials and Planned Corrective Actions: Management concurs with the audit finding and acknowledges that, during the fiscal year ended June 30, 2025, the C...

Finding 2025-003: Gramm-Leach-Bliley Act (GLBA) Significant Deficiency in Internal Control over Compliance / Other Matters Views of Responsible Officials and Planned Corrective Actions: Management concurs with the audit finding and acknowledges that, during the fiscal year ended June 30, 2025, the College had not performed penetration testing or completed an IT risk assessment as required under the Gramm-Leach-Bliley Act. Subsequent to fiscal year-end, management has taken decisive corrective action to remediate this deficiency and strengthen the College’s information security control environment:  Penetration Testing: Management engaged an independent, qualified third-party cybersecurity firm, Counter Measures Security, LLC, to perform penetration testing. A professional services agreement was executed in August 2025, and penetration testing was completed on October 17, 2025, in accordance with the Penetration Testing Execution Standard (PTES). Management has reviewed the results and is addressing identified recommendations as appropriate. Documentation supporting the completion of these services is retained by the College.  IT Risk Assessment and Information Security Program: Management is formalizing an IT risk assessment process consistent with GLBA requirements and incorporating penetration testing results into the College’s broader information security program.  Ongoing Monitoring: Management will establish a recurring schedule for penetration testing and IT risk assessments and will maintain documentation of results, remediation efforts, and management review to support ongoing compliance. Penetration testing was completed as of October 17, 2025, and management expects the IT risk assessment process and ongoing monitoring controls to be fully implemented during fiscal year 2026.

View Audit 404302

Finding 1218109 (2025-002)

Material Weakness 2025

Chestnut Hill College

PA

Student Financial Aid Reporting Significant Deficiency

Finding 2025-002: National Student Loan Database System (NSLDS) Reporting Significant Deficiency in Internal Control over Compliance / Other Matters Views of Responsible Officials and Planned Corrective Actions: Management concurs with the audit findings and acknowledges that controls over accurate ...

Finding 2025-002: National Student Loan Database System (NSLDS) Reporting Significant Deficiency in Internal Control over Compliance / Other Matters Views of Responsible Officials and Planned Corrective Actions: Management concurs with the audit findings and acknowledges that controls over accurate and timely reporting of student enrollment information to the NSLDS were not operating effectively, including procedures related to oversight of reporting performed by a third-party servicer. To address this finding, management is implementing the following corrective actions:  Management is evaluating and formalizing its oversight procedures related to NSLDS submissions performed by the third-party servicer, including defined responsibilities, review procedures, and escalation protocols.  Periodic internal reviews of NSLDS submissions are being implemented to verify the accuracy and timeliness of campus-level and program-level enrollment reporting.  Management is updating policies and procedures to ensure that all enrollment status changes and effective dates are captured and reported in accordance with U.S. Department of Education regulations. Management expects these corrective actions to be substantially implemented and will continue to monitor compliance to prevent recurrence.

View Audit 404302

Finding 1216640 (2025-004)

Material Weakness 2025

Hinds Community College District

MS

Student Financial Aid Questioned Costs Special Tests & Provisions

a. Administrator: V.P. Finance/ CFO ................... Victor Parker 601-857-3961 b. Administrator: V.P. Student Services ....... Jennifer Scott-Gilmore 601-857-3250 Student Financial Assistance Cluster: The District did not properly calculate the total amount disbursed or to be disbursed which lea...

a. Administrator: V.P. Finance/ CFO ................... Victor Parker 601-857-3961 b. Administrator: V.P. Student Services ....... Jennifer Scott-Gilmore 601-857-3250 Student Financial Assistance Cluster: The District did not properly calculate the total amount disbursed or to be disbursed which lead to incorrect calculation of funds to be returned to Title IV. Additionally, the District did not provide evidence of date of determination used in calculation. Corrective Action Plan: The District is an attendance taking institutional and has reviewed its internal controls on how total days in the semester are calculated correctly and timely disbursements are made. The District understands that it should be using the Last Day of Attendance in the calculation of earned aid and made that modification Spring 2025 in collaboration with the U.S. Department of Education and outlined the calculation variables to align with that calculation change. Management has revised its Policy and Procedures accordingly and was submitted to the Hinds Board of Trustees for final approval December of 2025. The correction implementation date was June 2025 and finalized December 2025. With the corrected action initially taking place June 2025, this will be a continuation into this FY2025 audit. The correction implementation date was June 2025 and finalized December 2025. With the corrected action initially taking place June 2025, this will be a continuation into this FY2025 audit.

View Audit 403102

Finding 1216636 (2025-003)

Material Weakness 2025

Hinds Community College District

MS

Student Financial Aid Special Tests & Provisions

a. Administrator: V.P. Finance/ CFO ................... Victor Parker 601-857-3961 b. Administrator: V.P. Student Services ....... Jennifer Scott-Gilmore 601-857-3250 Student Financial Assistance Cluster: The District did not report timely and accurate student status information to the National Stud...

a. Administrator: V.P. Finance/ CFO ................... Victor Parker 601-857-3961 b. Administrator: V.P. Student Services ....... Jennifer Scott-Gilmore 601-857-3250 Student Financial Assistance Cluster: The District did not report timely and accurate student status information to the National Student Loan Data System (NSLDS). The District did not ensure internal controls were in place to ensure timely and accurate reporting. Corrective Action Planned: The Management has implemented additional organizational and internal controls to ensure students' enrollment statuses are reported timely and accurately. In reviewing the causation of the finding, it was determined that it was a personnel error and as of June 2024, there is a new Registrar for Hinds Community College charged with compliance of this requirement. During the AY2024-25, the Registrar worked within the new student information system (SIS) to generate the required student data on a monthly cycle to be submitted to the National Clearinghouse which is then transmitted to NSLDS. This update in internal controls should satisfy future reviews. The correction date was July 2024. With the corrected action taking place July 2024, this will be a continuation into this FY2025 audit.

View Audit 403102

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