Corrective Action Plans

Finding 1160270 (2025-001)

Material Weakness 2025

The Episcopal Theological Seminary of the Southwest

TX

Student Financial Aid Eligibility Questioned Costs

Corrective Action Plan (CAP for Finding 2025-001) Date: 2 October 2025 Responsible official: Frederick L. Clement, Executive Vice President Management has corrected the finding by taking the following action: First, the institution entered into a professional services agreement with Higher Education...

Corrective Action Plan (CAP for Finding 2025-001) Date: 2 October 2025 Responsible official: Frederick L. Clement, Executive Vice President Management has corrected the finding by taking the following action: First, the institution entered into a professional services agreement with Higher Education Assistance Group to provide a comprehensive business process review of its financial aid operations. The objective of this review is to improve upon the functionality of processes, internal controls, and systems to ensure regulatory compliance and the effectiveness of service deliverables to students receiving financial aid. This review will include updates to policies, procedures, and internal controls for the import and export of electronic records, document tracking and file review, packaging and awarding, satisfactory academic progress, disbursement and reconciliation, withdrawal and Return to Title IV. Workflow and gap analysis will be performed to ensure intraoffice Title IV program compliance and best practices. Second, the institution has entered into a professional services agreement with Higher Education Assistance Group to provide interim staffing and third-party federal student aid processing including, but not limited to, counseling students and families on financial aid options, assisting with the management of Federal Direct Loan and Federal Graduate PLUS Loan programs to include student eligibility, file review, awarding, and origination and disbursement authorization using Populi, COD and other Department of Education software. In addition, Higher Education Assistance Group will provide additional Title IV training for personnel involved in federal student aid processing. With more than 35 years of experience, Higher Education Assistance Group and its team of seasoned consultants, all of whom have worked in federal student aid administration, whether in public/private colleges and universities or for the Department of Education itself, specializes in the compliant administration of Title IV student financial aid programs. The institution will adopt a supplemental internal control to cross-check student eligibility for Direct PLUS loans to ensure that an over-award is not originated and disbursed. Anticipated completion date: November 15, 2025

View Audit 370654 Questioned Costs: $1

Finding 1160239 (2025-002)

Material Weakness 2025

Northwest University

WA

Student Financial Aid Questioned Costs Reporting

Auditors noted that for two of the six sampled students, funds were returned to ED more than 45 days after the date the University determined the student had withdrawn. For one selection, a Return of Title IV calculation was performed timely, but an administrative error caused the disbursement to be...

Auditors noted that for two of the six sampled students, funds were returned to ED more than 45 days after the date the University determined the student had withdrawn. For one selection, a Return of Title IV calculation was performed timely, but an administrative error caused the disbursement to be delayed eight months. For the second selection, the University was notified of withdrawal in early March 2025 and student was included in registrar’s withdrawal listing, but was missed in review by Student Financial Services until late April 2025. Contact Person(s): Vickie Rekov, VP Enrollment Services; Roger Wilson, Associate Director of Financial Aid, SFS; Ryan Porter, CFO and Bernie Rundquist, Controller Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: All employees in Student Financial Services and Accounting Office involved in the reporting, distribution, drawdown and return of federal funds have reviewed the criteria under 34 CFR 668.22 The two departments involved will be meeting in the month of September 2025 to review policies and procedures to ensure controls exist and are well documented to ensure funds are returned timely. In-charge personnel will gather training resources to educate those involved in the reporting, disbursement and return of Title IV Funds. Anticipated completion date: October 2025

View Audit 370626

Finding 1159711 (2025-001)

Material Weakness 2025

Chapman University and Affiliates

CA

Student Financial Aid Reporting

The Office of the University Registrar and the Office of the Law Registrar have reviewed current policies and procedures related to the reporting of status changes in NSLDS. The Office of the Law Registrar will report status changes to National Student Clearinghouse no later than 30 days after degre...

The Office of the University Registrar and the Office of the Law Registrar have reviewed current policies and procedures related to the reporting of status changes in NSLDS. The Office of the Law Registrar will report status changes to National Student Clearinghouse no later than 30 days after degree conferral but no later than June 30. In additional they will follow up with NSC three business days after submission to verify that the file was received and processed correctly. The Law School does not confer degrees year-round. Based on the ABA accreditation and program plan, Fowler School of Law has three conferral dates: January 31, June 10, and September 1. Most students are conferred on June 10. The Office of the University Registrar will report enrollment status changes to the National Student Clearinghouse every 30 days. Unlike the Law school, the University Registrar’s office confers degree year-round. The registrar’s office is scheduled to submit a Degree Verify file every two weeks to the clearinghouse and will review students in submited degree file for accuracy in our reporting.

View Audit 370308

Finding 1159573 (2025-001)

Material Weakness 2025

Baylor University

TX

Student Financial Aid Reporting Subrecipient Monitoring

Federal and State Financial Assistance Programs Year Ended May 31, 2025 CORRECTIVE ACTION PLAN Audit Finding Reference: 2025-001 Planned Corrective Action: The University conducted a full review of the population of cancellations for the fiscal year ending May 31, 2025, comprising of 53 students. Th...

Federal and State Financial Assistance Programs Year Ended May 31, 2025 CORRECTIVE ACTION PLAN Audit Finding Reference: 2025-001 Planned Corrective Action: The University conducted a full review of the population of cancellations for the fiscal year ending May 31, 2025, comprising of 53 students. The review identified seven instances of late reporting, all of which were previously corrected through the University’s monthly disbursement reconciliation processes, but beyond the 15 calendar day reporting requirement. Each of the identified instances resulted from a system defect which caused canceled BBAY Direct Loans reduced to zero (“0”) to receive an automatic null attendance cost. Due to the automatic null value, the record was excluded from the financial aid management system to COD record extraction process. The University has created a report to identify instances where the attendance cost value is null. When identified, action will be taken to populate the attendance cost to zero and allow extraction. The records will be subsequently verified to confirm extraction for submission to COD and reports will be reviewed weekly by the supervisor. The University will continue to review and implement additional controls to ensure disbursement records are submitted to COD within 15 calendar days. To ensure enhanced oversight and monitoring controls are effective to maintain compliance and timely reporting to COD, management will incorporate this review into their routine Assurance validation processes for students from the identified population. These remediation efforts and risk management strategies will continue to be reviewed and implemented throughout fiscal year 2026. The University continues to update controls as needed to ensure compliance with an estimated completion date of May 31, 2026. Contact Person: Suzanne Weems Controller Baylor University Phone: (254) 710-3731

View Audit 370219

Finding 1153477 (2025-002)

Material Weakness 2025

The Corporation of Gonzaga University

WA

Student Financial Aid Questioned Costs Special Tests & Provisions

FINDING 2025‐002 – Special Tests and Provisions – Return of Title IV (R2T4) Funds Significant Deficiency in Return of Title IV Funds Processing Recommendation: The University should enhance its monitoring and review procedures to ensure that all unofficial withdrawals are identified and reported wit...

FINDING 2025‐002 – Special Tests and Provisions – Return of Title IV (R2T4) Funds Significant Deficiency in Return of Title IV Funds Processing Recommendation: The University should enhance its monitoring and review procedures to ensure that all unofficial withdrawals are identified and reported within the federally required timeframe. Strengthening this process will support the timeliness of federal compliance. Response: There is no disagreement with this audit finding. Action taken in response to finding: Some of the corrective actions noted in our response to finding 2025-001 also apply here. For example, quality assurance reports to identify students who withdraw from all classes in a part of term and the upcoming joint training and process mapping session with Student Financial Services and the Registrar’s Office will strengthen understanding of how enrollment status updates drive downstream compliance, including R2T4 processing. These steps will also ensure exceptions are addressed consistently and that communication channels between offices are clear. To address immediate gaps specific to R2T4 compliance, the Registrar’s Office has enhanced training regarding R2T4 compliance requirements related to recording withdrawals and enrollment changes in a timely, accurate and consistent manner. Additional quality checks are being implemented to confirm that withdrawal dates and status changes are entered accurately into the student information system so that R2T4 calculations are completed within federal timeframes. Together, these interventions are designed to ensure the timeliness and accuracy of R2T4 processing and compliance with federal requirements. We expect to have these corrective actions completed by September 12, 2025. Contact Person(s): Sarah Everitt, Dean of Student Financial Services; Maxwell Kwenda, University Registrar & Director of Institutional Research

View Audit 366726

Finding 1153470 (2025-001)

Material Weakness 2025

The Corporation of Gonzaga University

WA

Student Financial Aid Special Tests & Provisions Reporting

FINDING 2025‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a reconciliation between the system of record and the reporting system to ensure all student changes (enrollment status an...

FINDING 2025‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a reconciliation between the system of record and the reporting system to ensure all student changes (enrollment status and address changes) are reported on a timely basis. Response: There is no disagreement with this audit finding. Action taken in response to finding: Gonzaga has already taken action and implemented quality assurance reports and monitoring to ensure all student changes (enrollment status and address changes) are reported timely. Additionally, to strengthen compliance going forward, Student Financial Services and the Registrar’s Office are partnering to conduct a joint annual training and process mapping session for key personnel. This session will provide an overview of enrollment reporting requirements, outline the steps needed when exceptions to normal policies occur, and evaluate processes to improve understanding of how decisions affect both upstream and downstream functions. The session will also focus on building a shared understanding of reporting processes, identifying gaps in procedures and knowledge, and establishing communication channels so that exceptions are addressed timely, consistently and appropriately. These actions are designed to enhance internal controls and ensure compliance of timely reporting between the system of record and the reporting system, and we expect to complete this training by September 12, 2025. Contact Person(s): Sarah Everitt, Dean of Student Financial Services; Maxwell Kwenda, University Registrar & Director of Institutional Research

View Audit 366726

Finding 575411 (2025-002)

Significant Deficiency 2025

Andrews University

MI

Student Financial Aid Questioned Costs Special Tests & Provisions

Views of Responsible Officials and Planned Corrective Actions – To address the identified issues related to student withdrawal processing and Return to Title IV (R2T4) calculations, the University will implement the following steps: 1. Process Review and Collaboration: A joint meeting will be held w...

Views of Responsible Officials and Planned Corrective Actions – To address the identified issues related to student withdrawal processing and Return to Title IV (R2T4) calculations, the University will implement the following steps: 1. Process Review and Collaboration: A joint meeting will be held with key personnel from Academic Records and Financial Aid to review current withdrawal procedures, including the use of drop and exit forms. Emphasis will be placed on ensuring that appropriate withdrawal codes are consistently applied to support accurate and automated R2T4 processing. The goal is to establish a unified and clearly documented process that meets the operational needs of both departments. 2. Systematic Scheduling and Monitoring: Withdrawal-related tasks, including the running of BANNER return reports and other custom reports developed by the IT team, will be scheduled at regular intervals to ensure timely identification and processing of student withdrawals. These tasks will be integrated into departmental calendars, with scheduled dates already entered for the Fall 2025 and Spring 2026 semesters. 3. Ongoing Oversight and Communication: A communication protocol will be developed to ensure that all relevant documentation, including drop forms, is consistently shared between departments. This will help prevent delays in processing and ensure compliance with federal financial aid regulations.

View Audit 365458

Finding 575409 (2025-001)

Significant Deficiency 2025

Andrews University

MI

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Views of Responsible Officials and Planned Corrective Actions – The National Student Clearinghouse (NSC) Graduation and Enrollment Change Status’ submission calendar will be updated to reflect the necessary reporting timeline. The report will be completed after verification of graduation requirement...

Views of Responsible Officials and Planned Corrective Actions – The National Student Clearinghouse (NSC) Graduation and Enrollment Change Status’ submission calendar will be updated to reflect the necessary reporting timeline. The report will be completed after verification of graduation requirements and credentialing are completed by the Academic Record’s Department. Additional training will be provided to all members within the department to ensure timely submissions.

View Audit 365458

Finding 572429 (2025-001)

Significant Deficiency 2025

Regis University

CO

Student Financial Aid Questioned Costs Special Tests & Provisions

Finding 2025-001 Personnel Responsible for Corrective Action: Deborah Vinnola, Registrar Anticipated Completion Date: September 30, 2025 Corrective Action Plan: The Office of the Registrar has put into place a more detailed corrective action plan regarding the finding of delayed enrollment and non...

Finding 2025-001 Personnel Responsible for Corrective Action: Deborah Vinnola, Registrar Anticipated Completion Date: September 30, 2025 Corrective Action Plan: The Office of the Registrar has put into place a more detailed corrective action plan regarding the finding of delayed enrollment and non-enrollment reporting to NSLDS through NSC. The Office of the Registrar has adjusted the Degree Verify submission from every 45 days to every 30 days to NSC to ensure graduation dates are reported in a more timely fashion for NSLDS within the required 60 days for financial aid. Starting Summer 2025, the Office of the Registrar has begun inactivating academic programs for students who have not had registration activity within the last two to three academic years to ensure that they are not reported as enrolled to NSC/NSLDS. NSC Enrollment Reporting will continue to be submitted every 30 days and the Office of the Registrar has worked to review the reporting criteria using terms and not semesters to better report active enrollment in current courses. The Ellucian Graduation Application form and process is in the final stages of testing which will eliminate completely the need to add a pseudo course with a future date after the student’s current program has been inactivated or graduated. The Office of the Registrar will be more proactive with the colleges for identifying students who have not graduated within the six year (undergraduate), four year (graduate) and certificate time frames by working with the appropriate dean’s offices. This should eliminate those students who have completed their coursework; close to completing their coursework but were never reviewed by their advisor/program for graduation. Since Regis uses the end date of the last course completed, the Office of the Registrar will work with advising units to review the lists to increase a better reporting of degree completion.

View Audit 363564

Finding 570847 (2025-001)

Significant Deficiency 2025

Cornish College of the Arts and Cornish Foundation

WA

Questioned Costs Student Financial Aid Reporting

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

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The student that was incorrectly coded as FWS funds, the funds were immediately reclassified as institutional aid. Since Cornish, did not draw down all FWS funding, it did not impact the G5 drawdown and no needs needed to be returned. Going forward, a higher-level review will be conducted for students with high SAI and low need to ensure that no need-based funds, if not eligible, are in the packaging. This review, will take place after the initial counselor review, but before a student can begin working in the FWS program. This third check will ensure that these types of files are again reviewed in a timely manner and no over awards will happen in the future. Name(s) of the contact person(s) responsible for corrective action: Sara Drummond Planned completion date for corrective action plan: June 16th, 2025

View Audit 361771

Finding 1228920 (2024-013)

Material Weakness 2024

Twin Oaks Juvenile Development, Inc.

FL

Student Financial Aid Subrecipient Monitoring Reporting § 200.303

Twin Oaks will establish procedures for the review of all program reports prior to submission to the grantors, as well as documentation of that review. We have reduced significantly the amount of time to generate accurate reports but there may be more issues in 2025 due to the timing of establishing...

Twin Oaks will establish procedures for the review of all program reports prior to submission to the grantors, as well as documentation of that review. We have reduced significantly the amount of time to generate accurate reports but there may be more issues in 2025 due to the timing of establishing these procedures. Felecia Read will be responsible for making sure these are completed and documented.

View Audit 410428

Finding 1227907 (2024-014)

Material Weakness 2024

Arkansas Baptist College

AR

Student Financial Aid

2024 – 014 – Fiscal Operations Report and Application to Participate (FISAP) The Institution concurs with this finding. With new leadership and processes, Arkansas Baptist College will continue to enhance and strengthen its internal controls over the preparation and retention of documentation suppor...

2024 – 014 – Fiscal Operations Report and Application to Participate (FISAP) The Institution concurs with this finding. With new leadership and processes, Arkansas Baptist College will continue to enhance and strengthen its internal controls over the preparation and retention of documentation supporting the Fiscal Operations Report and Application to Participate (FISAP). Leadership will continue to make changes to implement stronger procedures to maintain complete supporting documentation for all amounts and information reported on the FISAP, reconcile reported information to the institution's financial aid, student information, and accounting records, retain evidence of the completed FISAP submission, and require supervisory review of the supporting documentation prior to submission of the report. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 409803

Finding 1227906 (2024-012)

Material Weakness 2024

Arkansas Baptist College

AR

Student Financial Aid Subrecipient Monitoring Reporting

2024 – 012 – Inaccurate Aid Disbursement Record The Institution concurs with this finding. Arkansas Baptist College accepts the recommendation to strengthen its internal controls over Title IV disbursement reporting by implementing procedures to ensure Title IV disbursement reports are complete, acc...

2024 – 012 – Inaccurate Aid Disbursement Record The Institution concurs with this finding. Arkansas Baptist College accepts the recommendation to strengthen its internal controls over Title IV disbursement reporting by implementing procedures to ensure Title IV disbursement reports are complete, accurate, and reconciled to the institution's financial aid and student accounting records. Leadership will continue to work to enhance and utilize Jenzabar reports to reconcile Title IV disbursement activity to student billing records on a regular basis, investigate and resolve discrepancies prior to using the reports for reporting or audit purposes, maintain documentation supporting reconciliations, and require supervisory review of the reconciliation process. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 409803

Finding 1227905 (2024-010)

Material Weakness 2024

Arkansas Baptist College

AR

Subrecipient Monitoring Reporting Student Financial Aid § 200.512

2024 – 010 – Late Submission of Audit Report The Institution concurs with this finding. With new leadership and administration, Arkansas Baptist College will adhere to its policies, procedures, processes, and federal guidelines as it relates to completing and submitting the audit. Arkansas Baptist C...

2024 – 010 – Late Submission of Audit Report The Institution concurs with this finding. With new leadership and administration, Arkansas Baptist College will adhere to its policies, procedures, processes, and federal guidelines as it relates to completing and submitting the audit. Arkansas Baptist College has a new CFO and controller. These measures will ensure stability and a timely audit.

View Audit 409803

Finding 1227904 (2024-008)

Material Weakness 2024

Arkansas Baptist College

AR

Student Financial Aid

2024 – 008 – Aid in Excess of Documented Need The Institution concurs with this finding. Under new leadership, Arkansas Baptist College will adhere to its policies, procedures, processes, and federal guidelines as it relates to over-awarding students, as well as ensure automated processes are implem...

2024 – 008 – Aid in Excess of Documented Need The Institution concurs with this finding. Under new leadership, Arkansas Baptist College will adhere to its policies, procedures, processes, and federal guidelines as it relates to over-awarding students, as well as ensure automated processes are implemented properly and fully tested to ensure such. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 409803

Finding 1227903 (2024-007)

Material Weakness 2024

Arkansas Baptist College

AR

Student Financial Aid Eligibility

2024 – 007 – Satisfactory Academic Progress The Institution concurs with this finding. Arkansas Baptist College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to students meeting satisfactory academic progress. Arkansas Baptist College h...

2024 – 007 – Satisfactory Academic Progress The Institution concurs with this finding. Arkansas Baptist College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to students meeting satisfactory academic progress. Arkansas Baptist College has an SAP appeal committee in place to enforce and abide by Arkansas Baptist College's policy. Responsible Administrators: Director of Financial Aid Effective: Immediately and ongoing

View Audit 409803

Finding 1227902 (2024-005)

Material Weakness 2024

Arkansas Baptist College

AR

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring

2024 – 005 – Verification The Institution, Arkansas Baptist College, accepts the recommendation and will continue to work and strengthen its internal controls over the verification process by implementing procedures to ensure that all required verification documentation is obtained, reviewed, and re...

2024 – 005 – Verification The Institution, Arkansas Baptist College, accepts the recommendation and will continue to work and strengthen its internal controls over the verification process by implementing procedures to ensure that all required verification documentation is obtained, reviewed, and retained prior to disbursing Title IV financial assistance. Management will use Jenzabar to monitor students selected for verification, maintain complete verification files supporting all required verification procedures, and require an additional level of review to verify that the required documentation has been received and eligibility has been established before aid is awarded or disbursed. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 409803

Finding 1227897 (2024-002)

Material Weakness 2024

Arkansas Baptist College

AR

Student Financial Aid

2024-002 Financial Management The Institution concurs with this finding. Under new and experienced leadership, Arkansas Baptist College will implement processes to ensure accurate attendance and participation records. Arkansas Baptist College will calculate R2T4s accurately and will return the funds...

2024-002 Financial Management The Institution concurs with this finding. Under new and experienced leadership, Arkansas Baptist College will implement processes to ensure accurate attendance and participation records. Arkansas Baptist College will calculate R2T4s accurately and will return the funds in a timely manner. Arkansas Baptist College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to R2T4 regulations. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 409803

Finding 1227896 (2024-013)

Material Weakness 2024

Arkansas Baptist College

AR

Student Financial Aid Eligibility Subrecipient Monitoring

2024 – 013 – Annual Loan Limit / PLUS Denial The Institution concurs with this finding. Under new leadership, Arkansas Baptist College accepts the recommendation to strengthen its internal controls over the Federal Direct Loan awarding process by implementing procedures to ensure dependent students ...

2024 – 013 – Annual Loan Limit / PLUS Denial The Institution concurs with this finding. Under new leadership, Arkansas Baptist College accepts the recommendation to strengthen its internal controls over the Federal Direct Loan awarding process by implementing procedures to ensure dependent students are awarded additional Federal Direct Unsubsidized Loan funds only when they meet the eligibility requirements prescribed by federal regulations. Leadership will continue to utilize Jenzabar to identify students receiving additional unsubsidized loan funds, verify and retain documentation of Direct PLUS Loan denials or other qualifying exceptions before disbursement, establish system edits or manual review procedures to prevent awards from exceeding applicable annual loan limits, and require supervisory review of all additional unsubsidized loan awards prior to disbursement. Responsible Administrators: Director of Financial Aid Effective: Immediately and ongoing

View Audit 409803

Finding 1227894 (2024-011)

Material Weakness 2024

Arkansas Baptist College

AR

Student Financial Aid Subrecipient Monitoring Eligibility

2024 – 011 – Aggregate Loan Limits The Institution concurs with this finding and accepts the recommendation for leadership to implement immediate steps to ensure that students receive their loan funds as required by Title IV regulations. Responsible Administrators: Director of Financial Aid & Chief ...

2024 – 011 – Aggregate Loan Limits The Institution concurs with this finding and accepts the recommendation for leadership to implement immediate steps to ensure that students receive their loan funds as required by Title IV regulations. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 409803

Finding 1227890 (2024-006)

Material Weakness 2024

Arkansas Baptist College

AR

Student Financial Aid Subrecipient Monitoring Special Tests & Provisions

2024 – 006 – Student Withdrawal Monitoring The Institution concurs with this finding. The College accepts the recommendation and will continue to enhance and strengthen its internal controls over the student withdrawal process by implementing procedures to ensure all student withdrawals are accurate...

2024 – 006 – Student Withdrawal Monitoring The Institution concurs with this finding. The College accepts the recommendation and will continue to enhance and strengthen its internal controls over the student withdrawal process by implementing procedures to ensure all student withdrawals are accurately identified, documented, and communicated in a timely manner between the Registrar's Office and the Financial Aid Office. The Institution will implement strong processes to reconcile withdrawal records maintained in Jenzabar with financial aid records on a regular basis, verify that all withdrawn students are evaluated for continued Title IV eligibility and Return of Title IV Funds requirements, and require supervisory review of the reconciliation process to ensure no withdrawn students are omitted from the withdrawal listing. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 409803

Finding 1227889 (2024-004)

Material Weakness 2024

Arkansas Baptist College

AR

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring

2024 - 004 - Student Credit Balance The Institution concurs with this finding. Arkansas Baptist College will review and adhere to its practices, policies, and procedures along with federal regulations as it relates to resolving credit balances. Arkansas Baptist College will resolve credit balances i...

2024 - 004 - Student Credit Balance The Institution concurs with this finding. Arkansas Baptist College will review and adhere to its practices, policies, and procedures along with federal regulations as it relates to resolving credit balances. Arkansas Baptist College will resolve credit balances in a timely manner within the 14-day period as defined in the Federal guidelines. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 409803

Finding 1227888 (2024-003)

Material Weakness 2024

Arkansas Baptist College

AR

Student Financial Aid Subrecipient Monitoring Reporting

2024 -003 - Common Origination and Disbursement (COD) System The Institution concurs with this finding. Arkansas Baptist College will ensure the accuracy of the data that is input into the COD system, and Arkansas Baptist College will work to apply funds appropriately to students' accounts. Arkansas...

2024 -003 - Common Origination and Disbursement (COD) System The Institution concurs with this finding. Arkansas Baptist College will ensure the accuracy of the data that is input into the COD system, and Arkansas Baptist College will work to apply funds appropriately to students' accounts. Arkansas Baptist College will review, revise, and adhere to its practices, policies, and procedures along with federal guidelines as it relates to managing the COD system. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 409803

Finding 1227886 (2024-009)

Material Weakness 2024

Arkansas Baptist College

AR

Student Financial Aid Eligibility Subrecipient Monitoring

2024 – 009 – Pell Grant Calculations The Institution concurs with this finding. Arkansas Baptist College will adhere to its policies, procedures, processes, and federal guidelines as it relates to calculating and awarding Pell. Arkansas Baptist College will return any ineligible Management funds acc...

2024 – 009 – Pell Grant Calculations The Institution concurs with this finding. Arkansas Baptist College will adhere to its policies, procedures, processes, and federal guidelines as it relates to calculating and awarding Pell. Arkansas Baptist College will return any ineligible Management funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 409803

Finding 1226821 (2024-058)

Material Weakness 2024

Oklahoma Water Resources Board

OK

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

Finding Number 2024-058 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 – TANF Planned Corrective Action OKDHS agrees that controls supporting the compilation and validation of the Child Welfare Services (CWS) population used in the TANF allocation methodology can be strength...

Finding Number 2024-058 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 – TANF Planned Corrective Action OKDHS agrees that controls supporting the compilation and validation of the Child Welfare Services (CWS) population used in the TANF allocation methodology can be strengthened. OKDHS will enhance procedures used to compile and validate the population included in the Child Welfare Services TANF allocation methodology. Management will implement additional review procedures to verify that participants included in the allocation methodology meet the applicable eligibility criteria established by the Oklahoma TANF State Plan and that supporting documentation is available to substantiate eligibility. The agency will also formalize review procedures for the preparation and approval of the allocation calculation, including validation of source data used to determine the applicable percentage applied to Child Welfare Services contract expenditures. These procedures will include management review of supporting documentation and reconciliation of the underlying population prior to completion of the allocation methodology. These enhancements are intended to strengthen internal controls over the allocation process, improve the reliability of the supporting data, and provide greater assurance that expenditures charged to the TANF program are based on an accurately supported eligible population. Anticipated Completion Date In Progress Responsible Contact Person Kayla Urtz

View Audit 409119

Corrective Action Plans

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