Corrective Action Plans

Finding 516378 (2024-004)

Material Weakness 2024

OR

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

Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and a...

Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have documented and tested enrollment reporting to National Student Clearinghouse from our new SIS, Colleague. NSC is working with us to get our enrollment current. Once hired, our Dean of Students / Registrar will partner with the Enrollment Systems Analyst to ensure enrollment reporting is timely and accurate. Name(s) of the contact person(s) responsible for corrective action: Dean of Students (Interim Sarah Geleynse, position to be hired Winter 2025) Planned completion date for corrective action plan: 6/30/2025

View Audit 334325

Finding 516374 (2024-003)

Material Weakness 2024

Clatsop Community College

OR

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

Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action t...

Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have implemented a plan to review monthly each outstanding check to ensure that all funds are returned to the Federal programs if appropriate. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Implemented in September 2024

View Audit 334325

Finding 516372 (2024-002)

Significant Deficiency 2024

Clatsop Community College

OR

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

Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. In addition, the College should revise their procedures to include documentation of the key control. Explanation...

Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. In addition, the College should revise their procedures to include documentation of the key control. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have updated our procedure to reconcile Pell and Loans twice monthly to be able to catch any reporting errors within the 15-day reporting window. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Implemented September 2024

View Audit 334325

Finding 516371 (2024-001)

Significant Deficiency 2024

Clatsop Community College

OR

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

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: The College changed systems since the end of this fiscal year, and we recommend the College review the auto-packaging rounding rules of its new system to ensure that the Pell award is calculated in accordance with federal...

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: The College changed systems since the end of this fiscal year, and we recommend the College review the auto-packaging rounding rules of its new system to ensure that the Pell award is calculated in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have implemented the auditor’s recommendation and thoroughly tested award rounding in the new SIS. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Implemented September 2024

View Audit 334325

Finding 516362 (2024-001)

Significant Deficiency 2024

Pacific Northwest University of Health Sciences

WA

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

Recommendation: The auditors recommend the University continue to focus on improving internal controls surrounding the calculation and posting of, as well as review of, budget adjustments. The auditors recommend further that the University ensure this process is well documented in a formal policy. A...

Recommendation: The auditors recommend the University continue to focus on improving internal controls surrounding the calculation and posting of, as well as review of, budget adjustments. The auditors recommend further that the University ensure this process is well documented in a formal policy. Action taken: Identified common causation factors that contributed to the finding. In this particular case, the student’s budget was adjusted more than once due to changes in both her graduation date and her tuition rate during her final year. Her budget was not adjusted correctly. The issues identified are: o Identifying when tuition charge has been adjusted. o Having another financial aid staff member review changes to the budget adjustment(s). The following actions were taken: o Reached out for assistance identifying students whose tuition has been reduced. Was provided with a report we can run before financial aid disburses, “FA Registration”, which will capture all changes to each student’s tuition. o Have included running this report in the steps completed prior to aid disbursement. o Reviewed and refined steps already in place, specifically addressing the processing of budgets for students who are off cycle during a semester. Steps are outlined in document “23-24 Budget Adjustment Quality Control Process” and include:  Templates to be used for correct budgets.  Assigned two-letter comment codes that will identify students with budget adjustment for off-cycle attendance.  Created a selection set in PowerFAIDS to capture students with these comment codes in a report.  Created a task in PowerFAIDS that will assign review of completed budget adjustments to a specific FA staff member. She will review the calculations and sign off on them. These actions have been implemented effective immediately. Name of Responsible Party: Laura Pendleton, Director of Financial Aid Anticipated completion date: October 30, 2024

View Audit 334218 Questioned Costs: $1

Finding 516361 (2024-001)

Significant Deficiency 2024

Manhattan School of Music

NY

Student Financial Aid

MSM remain stronly committed to timely and accurate reporting. NSC, MSM's 3rd party processor, investigated the matter and identified a breakdown of its standard processing procedure to notify an institution of any errors in uploaded files to NSLDS. Had NSC followed its standard, MSM would have resu...

MSM remain stronly committed to timely and accurate reporting. NSC, MSM's 3rd party processor, investigated the matter and identified a breakdown of its standard processing procedure to notify an institution of any errors in uploaded files to NSLDS. Had NSC followed its standard, MSM would have resubmitted the file to NSC, and no error or delay in reporting would have occurred Yes MSM acknowledges its responsibility for actions taken by third-party service providers. MSM has reinforced training for the Office of the Registrar staff related to NSC reporting and requested updates of its NSC procedure manual, inlcuding date validation that ensures accurate and timely submission of information to NSC from MSM and, ultimately, NSLDS. Specifically, the Office of the Registrar staff will complete live and on-demand webinards to reinforce knowledge and the strict adherence to federal reporting requirements and timeliness by the end of the calendar year 2024. In addition, training on NSC reporting from our Student Information System (SIS) (Jenzabar 1) will be conducted yearly, or as necessary when upgrades or patches are released affecting NSC reporting. MSM Office of the Registrar staff attended such training on November 25, 2024.

View Audit 334195

Finding 516286 (2024-004)

Significant Deficiency 2024

Western Oregon University

OR

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

Finding: 2024-004 Federal Agency Name: U.S. Department of EducationAssistance Listing Number(s): 84.007, 84.033, 84.038, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: Awards must be coordinated among the various programs and with other federal and nonfede...

Finding: 2024-004 Federal Agency Name: U.S. Department of EducationAssistance Listing Number(s): 84.007, 84.033, 84.038, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). Financial need is defined as the student’s COA minus the student’s EFC (as computed by the central processor and included on the student’s SAR/ISIR). During the testing of compliance for Eligibility, it was noted students who worked as Resident Advisors for the University, did not have their Title IV aid adjusted for amounts they received via direct payments to cover the cost of their housing. As a result, the University compensated the students for the cost of their housing outside the normal processing and packaging of Title IV aid, resulting in $26,572 of Direct Loans being disbursed to student’s in excess of their financial need. Responsible Individuals: Kella Helyer, Director of Financial Aid Corrective Action Plan: The current year (2024-25) Resident Assistant benefits have been taken into consideration for all applicable students. Anticipated Completion Date: 9/10/2024

View Audit 334105 Questioned Costs: $1

Finding 516280 (2024-003)

Significant Deficiency 2024

Western Oregon University

OR

Reporting Special Tests & Provisions Student Financial Aid

Finding: 2024-003 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.038, 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 ti...

Finding: 2024-003 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.038, 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 timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS. The University pushed through the changes in enrollment status to the Clearinghouse timely and accurately based upon the student’s enrollment status; however, the change in enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and untimely records within NSLDS. Responsible Individuals: Kella Helyer, Director of Financial Aid and Amy Clark, University Registrar Corrective Action Plan: There is documentation of the student’s enrollment status in the National Student Clearinghouse (NSC) for each month starting Fall term 2023. The enrollment reporting process functions such that each month, the National Student Loan Data System (NSLDS) sends a file to NSC for the students who have been awarded federal aid. NSC then sends a file back to NSLDS for the students on the list. This return file then updates the NSLDS enrollment reporting section in their system. NSC will not send enrollment for students if they are not on the NSLDS list. To do so would be a FERPA violation. For the student in question, NSLDS did not place their name on the list for reporting enrollment until June 2024. A second call to NSLDS has been placed requesting a response as to why this student was not reported. Anticipated Completion Date: 12/6/2024

View Audit 334105

Finding 516255 (2024-001)

Significant Deficiency 2024

Wingate University

NC

Student Financial Aid Special Tests & Provisions Reporting

Name of Responsible Individual: Maria Taylor, Registrar & Jenn Hall, Director of Financial Aid Corrective Action: It was identified during the Student Financial Aid audit that Wingate University (WU) is out of compliance with the enrollment reporting requirements for two students (one student at th...

Name of Responsible Individual: Maria Taylor, Registrar & Jenn Hall, Director of Financial Aid Corrective Action: It was identified during the Student Financial Aid audit that Wingate University (WU) is out of compliance with the enrollment reporting requirements for two students (one student at the campus level and one student at both the campus level and program level). We currently contract with the National Student Clearinghouse (NSC) for enrollment reporting and have identified the compliance issue to be a disconnect between the reporting requirements in place with NSC and WU Institutional policy. For each identified student, the student was permitted by WU policy to complete their degree requirements after the end of the academic term. When reporting the Graduated status in NSC, the Registrar is required to select the last date of the term as the Graduation Date instead of the date the student actually completed their degree requirements. When this occurs more than 60 days from the end of the term, the student is noted as out of compliance with reporting requirements due to the limitation identified with NSC. The Registrar and Director of Financial Aid will work with NSC to identify a solution for reporting the actual completion date for a student when it occurs after the conclusion of the standard term and outside of the reporting definitions offered by NSC. If a viable solution cannot be identified with NSC, we will establish a policy to manually update data in NSLDS for impacted students to meet the 60-day reporting requirements for enrollment status changes. Anticipated Completion Date: May 31, 2025

View Audit 334066

Finding 516145 (2024-002)

Significant Deficiency 2024

Riverside Community College District

CA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Views of Responsible Officials and Corrective Action Plan The College, with support from the District, will implement an annual review of compliance requirements and training for all staff associated with Return to Title IV calculation requirements to ensure that the data utilized in preparing the c...

Views of Responsible Officials and Corrective Action Plan The College, with support from the District, will implement an annual review of compliance requirements and training for all staff associated with Return to Title IV calculation requirements to ensure that the data utilized in preparing the calculation is accurate and that the College’s procedures are in line with compliance requirements of the program. Norco College Student Financial Services reviewed the workflow of Return to Title IV to enhance implementational procedures and regulatory compliance of this process. This will ensure that student withdrawal calculations are performed accurately and occur in a timely manner based on the District’s schedule of specific dates for each term of when calculations are completed. The purpose of these efforts is to meet compliance requirements as they are related to Return to Title IV. There was also staff turnover during the 2023-24 award year resulting in inconsistent procedures causing the two incorrect calculations and the lack of notification to the student of their eligible post withdrawal disbursement. An Assistant Director position was approved and filled as of May 2024. The Assistant Director takes an active role to ensure federal guidelines are adhered to, completes thorough training on a regular basis, and all calculations are reviewed for accuracy.

View Audit 333977

Finding 516138 (2024-001)

Significant Deficiency 2024

Riverside Community College District

CA

Student Financial Aid Eligibility Significant Deficiency

Views of Responsible Officials and Corrective Action Plan The College, with support from the District, will implement an annual review of compliance requirements and training for all staff associated with eligibility requirements for calculated disbursements amounts to ensure accuracy. Norco College...

Views of Responsible Officials and Corrective Action Plan The College, with support from the District, will implement an annual review of compliance requirements and training for all staff associated with eligibility requirements for calculated disbursements amounts to ensure accuracy. Norco College Student Financial Services reviewed the workflow and processing procedures of flagging student files in a timely manner for those that qualify for the additional Pell indicator. The intention of these efforts is to meet regulatory compliance requirements as they are related to student Pell eligibility when awarding and packaging students for additional Pell. There was staff turnover during the 2023-24 award year resulting in procedures misunderstood and not followed consistently which caused the student to not be flagged at the appropriate time in the awarding and disbursement process. An Assistant Director position was approved and filled as of May 2024. The Assistant Director is responsible for Pell grant payment oversight during the authorization and approval of the institution’s monthly disbursement process to ensure federal guidelines are adhered to. The Assistant Director has completed thorough training regarding the disbursement process and Pell eligibility. Additionally, training is conducted on a regular basis to review student Pell disbursement eligibility for accuracy.

View Audit 333977

Finding 516117 (2024-004)

None 2024

University of Hawaii

HI

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

Finding No. 2024-004: Financial Aid Administration - Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.268 – Federal Direct Student Loans Questioned Costs: $ - Responsible Individual: Jeff Anderson, Financial Aid Director Date Action Taken: November 14, 2024 ...

Finding No. 2024-004: Financial Aid Administration - Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.268 – Federal Direct Student Loans Questioned Costs: $ - Responsible Individual: Jeff Anderson, Financial Aid Director Date Action Taken: November 14, 2024 The institution was unable to perform exit counseling to the borrower in a timely manner due to competing priorities of the program staff at the time. To ensure these can be done within the given timeframe the financial aid team will re-visit processes as well as provide training to new staff as they are onboarded to ensure back plans are in place in the event that key personnel are out of the office during this timeframe.

View Audit 333933

Finding 516116 (2024-003)

None 2024

University of Hawaii

HI

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

Finding No. 2024-003: Financial Aid Administration - Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.268 – Federal Direct Student Loans Questioned Costs: $ - Responsible Individual: Anna Chamberlain, Financial Aid Director Date Action Taken: November 14, 20...

Finding No. 2024-003: Financial Aid Administration - Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.268 – Federal Direct Student Loans Questioned Costs: $ - Responsible Individual: Anna Chamberlain, Financial Aid Director Date Action Taken: November 14, 2024 Loan exit was not conducted within 30 days because of staffing and training issues. The Financial Aid Office now has adequate staff trained to review and perform loan exit counseling as required. The office has also developed written instructions for training in the event of turnover.

View Audit 333933

Finding 516115 (2024-002)

None 2024

University of Hawaii

HI

Student Financial Aid Internal Control / Segregation of Duties

Finding No. 2024-002: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.063 – Federal Pell Grant Questioned Costs: $ - Responsible Individual: Davileigh Naeole, Financial Aid Director Date Action Taken: November 12, 2024 To address...

Finding No. 2024-002: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.063 – Federal Pell Grant Questioned Costs: $ - Responsible Individual: Davileigh Naeole, Financial Aid Director Date Action Taken: November 12, 2024 To address the auditor’s findings and ensure timely processing of unofficial withdrawals, our strategy will be to implement an internal deadline in our office of 20 days for determining withdrawal dates, ahead of the 30-day required deadline. This will provide a buffer to manage delays and ensure compliance.

View Audit 333933

Finding 516114 (2024-001)

None 2024

University of Hawaii

HI

Questioned Costs Student Financial Aid Internal Control / Segregation of Duties

Finding No. 2024-001: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.063 – Federal Pell Grant Questioned Costs: $ 876 Responsible Individual: James Oshiro, Financial Aid Director Date Action Taken: August 15, 2024 This finding is...

Finding No. 2024-001: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.063 – Federal Pell Grant Questioned Costs: $ 876 Responsible Individual: James Oshiro, Financial Aid Director Date Action Taken: August 15, 2024 This finding is a result of a student return of Title IV funds after the R2T4 calculation was completed. At UH- West Oʻahu, student returns are returned by the university on the student’s behalf. With this finding, the student return portion of the R2T4 calculation was simply overlooked and was not returned to the federal government in a timely manner. A new staff member also took over the R2T4 duties about a year and a half ago. Once the student return was identified as not returned (nor failed to notify the student to repay the grant overpayment), the return was immediately completed and a full review of all R2T4 withdrawals for the award year was completed for any additional occurrences. There were no other student returns which was not completed. To prevent any future overlooked student returns, an R2T4 checklist was created to review the numerous steps in the R2T4 process in order to check ourselves.

View Audit 333933 Questioned Costs: $1

Finding 516073 (2024-002)

Significant Deficiency 2024

Maria L. Varisco-Rogers Charter School

NJ

Student Financial Aid Cash Management Internal Control / Segregation of Duties

In response to the indings from the Collaborative Federal Monitoring (CFM) Audit that was conducted on the Federal grants funding in FY 24, MLVR Charter school will be submitting a CFM CAP to homeroom. The CAP will address the following: ...

In response to the indings from the Collaborative Federal Monitoring (CFM) Audit that was conducted on the Federal grants funding in FY 24, MLVR Charter school will be submitting a CFM CAP to homeroom. The CAP will address the following: 1. Reimbursement requests will be submitted at a minimum quarterly otherwise every two months. 2. Accounting software is updated and reviewed to ensure budgeted amounts and carryover funds are properly recorded throughout the fiscal year.

View Audit 333875

Finding 515980 (2024-003)

Significant Deficiency 2024

Lawrence Technological University

MI

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

Condition: The University does not have all of the minimum safeguards written down within its information security program. Planned Corrective Action: This finding has already been addressed. During the current year testing, we updated our “GLBA Information Security Program”. While it does contain a...

Condition: The University does not have all of the minimum safeguards written down within its information security program. Planned Corrective Action: This finding has already been addressed. During the current year testing, we updated our “GLBA Information Security Program”. While it does contain all elements required, technically the policy was not updated until 7/25/2024. LTU followed up with the FSA Cyber Compliance Team regarding this finding from last year. We received the following response on August 15th, 2024: Thank you for providing evidence artifacts to the Federal Student Aid (FSA) Cybersecurity Compliance Team indicating that you have satisfied the minimum information security requirements of Gramm-Leach-Bliley Act (GLBA) at Lawrence Technological University for the audit year of 2023. As a courtesy, we remind you that all the GLBA Cybersecurity requirements are to be satisfied each audit year. Protecting student data is an utmost priority for FSA and we are committed to ensuring the safety and security of student information. We have reviewed the information you provided and determined it sufficient to close the case. Contact person responsible for corrective action: Linda L Height, VP Finance Anticipated Completion Date: July 25, 2024

View Audit 333819

Finding 515847 (2024-003)

Significant Deficiency 2024

University of Mount Olive, Inc.

NC

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Name of Responsible Individual: Ms. Terri Grice Corrective Action: The University has implemented a plan to review the NSLDS website within 10 Business Days of any submission to ensure that the submitted data has been processed correctly by Clearinghouse and NSLDS. Anticipated Completion Date: Decem...

Name of Responsible Individual: Ms. Terri Grice Corrective Action: The University has implemented a plan to review the NSLDS website within 10 Business Days of any submission to ensure that the submitted data has been processed correctly by Clearinghouse and NSLDS. Anticipated Completion Date: December 13, 2024

View Audit 333710

Finding 515844 (2024-001)

None 2024

University of Mount Olive, Inc.

NC

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Name of Responsible Individual: Mr. Brian K. Blackburn Corrective Action: As a result of Audit Finding 2023-001 the University had implemented a weekly COD Maintenance Files for Direct Loans and Pell Grants. The 2024-001 Finding is a result of an oversight in the setup of the one student record that...

Name of Responsible Individual: Mr. Brian K. Blackburn Corrective Action: As a result of Audit Finding 2023-001 the University had implemented a weekly COD Maintenance Files for Direct Loans and Pell Grants. The 2024-001 Finding is a result of an oversight in the setup of the one student record that caused the information to not be picked up and included in the weekly file. The problem has now been identified and corrected to ensure that such an oversight does not reoccur. Additionally, the University has implemented a new policy in terms of creating and updating student records. Anticipated Completion Date: December 9, 2024

View Audit 333710

Finding 515824 (2024-002)

Significant Deficiency 2024

Glen Oaks Community College

MI

Special Tests & Provisions Student Financial Aid Significant Deficiency

2024-002 – Return of Title IV Calculation. Auditor Description of Condition and Effect. A break of at least five consecutive days was not excluded from the reported enrollment period for the Winter 2024 semester, which resulted in the calculation being incorrect for all students who had returns in t...

2024-002 – Return of Title IV Calculation. Auditor Description of Condition and Effect. A break of at least five consecutive days was not excluded from the reported enrollment period for the Winter 2024 semester, which resulted in the calculation being incorrect for all students who had returns in the Winter 2024 semester. As a result of this condition, Return of Title IV calculations were incorrect for five students for the Winter 2024 semester, resulting in $66.52 in excess funds returned to the U.S. Department of Education. It is our understanding that on August 14, 2024, the College repaid the five students affected by this calculation error. Auditor Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is reviewed by a second individual. Corrective Action. Upon discovery of the Return of Title IV Calculation error, the College went through and made corrections to all student accounts affected. To prevent a similar problem from arising in the future, the College has developed a review process where the Director of Financial Aid will review break day regulations in the FSA handbook and verify that the Ellucian Colleague annual set-up has accurate break days. The Director of Financial Aid will also verify accuracy as calculations are processed for students. Responsible Party. Jean Zimmerman, Director of Financial Aid. Anticipated Completion Date. August 14, 2024.

View Audit 333681

Finding 515820 (2024-001)

Significant Deficiency 2024

Glen Oaks Community College

MI

Reporting Special Tests & Provisions Student Financial Aid

2024-001 – Timeliness of Status Change Reporting. Auditor Description of Condition and Effect. During our testing of thirteen students with status changes, we noted six instances of late reporting of a student's status changes. Three of these instances were winter term graduates whose status change...

2024-001 – Timeliness of Status Change Reporting. Auditor Description of Condition and Effect. During our testing of thirteen students with status changes, we noted six instances of late reporting of a student's status changes. Three of these instances were winter term graduates whose status change was reported one day late. The other three of these instances were winter term graduates whose status changes had not been reported as of the date of our audit fieldwork, due to a technical glitch in the College's reporting system. Therefore, the NSLDS system is not updated with the student information timely which could lead to a student's grace period being shortened. Auditor Recommendation. We recommend that the College review its reporting procedures to ensure that students' status changes are accurately and timely reported to NSLDS as required by regulators. Corrective Action. The Director of Financial Aid will review the reporting procedures to ensure that students' status changes are accurately and timely reported to NSLDS. The Director of Financial Aid will check NSLDS to ensure timely reporting. Responsible Party. Jean Zimmerman, Director of Financial Aid, and Amy Young, Registrar. Anticipated Completion Date. First Fall 2024 NSC reporting.

View Audit 333681

Finding 515819 (2024-001)

Significant Deficiency 2024

Ashland University

OH

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

The Registrar's Office has performed a further review of its policies and procedures to continue to ensure timely, accurate, and complete submission of enrollment records. The Registrar’s Office has updated its procedures to include response schedules with internal control mechanisms for monitoring ...

The Registrar's Office has performed a further review of its policies and procedures to continue to ensure timely, accurate, and complete submission of enrollment records. The Registrar’s Office has updated its procedures to include response schedules with internal control mechanisms for monitoring compliance with the seven-day response requirement to the Provost’s Office and processing requests for additional assistance as necessary. The updated response schedule includes a goal to respond to error reports within four days of receipt, with final submission no later than six days following notice of the error report, unless the Provost has been notified that enrollment updates have been suspended by National Student Clearinghouse while files are being processed, in which case the Registrar’s Office will monitor and document the processing status until the suspension has been raised. Any response which will exceed six days requires written notice to the Provost’s Office with a plan to complete the required enrollment updates by 5:00pm ET on the seventh day, and any request for additional assistance or resources necessary to do so. Members of the Registrar’s Office also participated in additional training through National Student Clearinghouse with respect to enrollment reporting and error report codes related to enrollment effective dates. Training related to enrollment reporting will be scheduled at least annually through the Registrar’s Office. Finding 2022-005 of the Final Audit Determination (FAD) found that student enrollment status effective dates required further updates following the initial data corrections which were completed in September 2023. In addition to review of its policies and procedures and training, the Registrar’s Office engaged with its third-party servicer for enrollment reporting to review the data reporting systems and integration, as well as the data and information reported by the servicer to the National Student Loan Data System (NSLDS), during its response to Finding 2022-005. In response to the required action for this finding, the University requested an extension and the extension was granted to complete the required action with the U.S. Department of Education Office of Federal Student Aid (FSA). FSA requested regular status reporting and the University complied with the reporting requirement. The status reporting included updates as to the progress of the review and the University’s methods for reviewing and updating the enrollment reports so that FSA could ensure timely and accurate progress was being achieved throughout the University’s completion of the required action. The University completed the required corrections within the extension timeline of September 30, 2024.

View Audit 333674

Finding 515767 (2024-002)

Significant Deficiency 2024

Otis College of Art and Design

CA

Student Financial Aid Reporting Special Tests & Provisions

November 18, 2024 Response to Finding 2024-002 Special Tests and Provisions - Enrollment Reporting Significant Deficiency in Internal Control over Compliance Otis College of Art and Design agrees with the finding. Responsible Office and Individual The Executive Director of Financial Aid and The One ...

November 18, 2024 Response to Finding 2024-002 Special Tests and Provisions - Enrollment Reporting Significant Deficiency in Internal Control over Compliance Otis College of Art and Design agrees with the finding. Responsible Office and Individual The Executive Director of Financial Aid and The One Stop, Michaela Matsumoto (mmatsumoto@otis.edu) and Registrar Nicole Raef (nraef@otis.edu) are the responsible individuals for implementation of the corrective action plan. Corrective Action Plan Upon review of the finding, Financial Aid administration met with the Registrar's staff to create a new procedure whereby immediate reporting of withdrawals are made directly to NSLDS in addition to the regularly scheduled monthly reports to NSLDS through the National Student Clearinghouse (NSC). This immediate reporting should elimnate any timing issues with the monthly reports through NSC. In addition, a joint effort to streamline the routing of withdrawal forms to the appropriate departments for faster processing is underway. This is reprocessing of the withdrawal forms will be implemented in the next 120 days.

View Audit 333609

Finding 515763 (2024-001)

Significant Deficiency 2024

Otis College of Art and Design

CA

Questioned Costs Special Tests & Provisions Student Financial Aid

November 18, 2024 Finding 2024-001 Special Tests and Provisions - Return of Title IV: Significant Deficiency in Internal Control over Compliance Otis College of Art and Design agrees with the Return of Title IV calculation finding. This error was noticed by new financial aid staff/administration hi...

November 18, 2024 Finding 2024-001 Special Tests and Provisions - Return of Title IV: Significant Deficiency in Internal Control over Compliance Otis College of Art and Design agrees with the Return of Title IV calculation finding. This error was noticed by new financial aid staff/administration hired in late spring of 2024 after the prior administration had completed all return of Title IV calculations except for the unofficial withdrawals. The new staff noticed the error and made the adjustment going forward starting with the unofficial withdrawals for spring 2024. This error only affected the days of Spring Break. No other semesters had an error in dates used in the Return of the Title IV calculations. Responsible Office and Individual The Executive Director of Financial Aid and The One Stop, Michaela Matsumoto (mmatsumoto@otis.edu) and Registrar Nicole Raef (nraef@otis.edu) are the responsible individuals for implementation of the corrective action plan. Corrective Action Plan Financial Aid Management met with the Registrar's Office to ensure all future semester set up dates are correct and have been reviewed. This improvement of processes to ensure a double check of the Return of Title IV calendar setup has been implemented for 2025-2026.

View Audit 333609 Questioned Costs: $1

Finding 515700 (2024-003)

Significant Deficiency 2024

Arizona Christian University

AZ

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Explanation of disagreement with audit finding: There i...

Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Continue reviewing student credit balances on a weekly basis ensuring Title IV refund checks are processed within the 14 calendar days. Additionally, the Finace team will review current procedure and draft a formal policy and procedure for Student Credit Balances. Name(s) of the contact person(s) responsible for corrective action: Michael Werner- VP of Finance Planned completion date for corrective action plan: End of Calendar year 2024

View Audit 333555

Corrective Action Plans

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