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Corrective Action Plans

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Finding 551391 (2024-004)
Material Weakness 2024
Hampton University
VA
Student Financial Aid Special Tests & Provisions Reporting
The University concurs with the finding. The University is working with the Clearinghouse and consultants to correct system errors within Banner, so we do not have these concerns in the future. The Architect students mapping issue was corrected by the Registrar Office in March 2025. The Registrar’s ...
The University concurs with the finding. The University is working with the Clearinghouse and consultants to correct system errors within Banner, so we do not have these concerns in the future. The Architect students mapping issue was corrected by the Registrar Office in March 2025. The Registrar’s Office has created a new program code that will reflect next semester’s registrations and updated previous majors.
View Audit 352091
Finding 551172 (2024-001)
Significant Deficiency 2024
Mercy College
NY
Student Financial Aid Reporting Eligibility
Corrective action: There is a process in Banner that creates a file containing graduates for degree verification submission to the National Student Clearinghouse. There was a systematic error with that process in Spring 2024 rendering the process unable to generate a file. The error was not resolved...
Corrective action: There is a process in Banner that creates a file containing graduates for degree verification submission to the National Student Clearinghouse. There was a systematic error with that process in Spring 2024 rendering the process unable to generate a file. The error was not resolved until May 2024, which is when the submission for these students was completed. This was a one-time specific system failure occurrence which has been resolved and the process has been working correctly since May 2024. The Offices of the Registrar and Student Financial Services are working in conjunction with the University compliance team and Office of Institutional Research to enhance review and checks/balances of reporting deadlines to ensure that files are submitted within the required deadlines. Further, the Office of the Registrar will work with internal IT staff to research and implement backup reporting procedures for creating enrollment and graduation files in the event of another system issue. Proposed Completion Date: May 31, 2024
View Audit 352071
Finding 551168 (2024-101)
Significant Deficiency 2024
Pima County Community College District
AZ
Questioned Costs Student Financial Aid Special Tests & Provisions § 200.303
Assistance Listings number and program name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans This finding initially occurred in fiscal year 2024. Name of Contact Person: David Donderew...
Assistance Listings number and program name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans This finding initially occurred in fiscal year 2024. Name of Contact Person: David Donderewicz, M. Ed., Executive Director of Financial Aid and Scholarships Anticipated completion date: June 30, 2025 Corrective Action: 1. Perform calculations for all students who received Title IV funds and withdrew during the period November 2023 through June 2024 and immediately return all unearned aid to ED. 2. Review and update the student information system’s automated controls to properly identify and flag all students who receive Title IV funds and withdraw from the District. 3. Test any changes made to the student information system and verify controls are operating as designed to comply with the SFA cluster’s requirements. The College concurs with the recommendations from the Arizona Auditor General. The College will conduct an additional review to identify any students who may have impacted financial aid adjustments and will enact any necessary corrections (estimated completion, 3/31/25). Additionally, the College will review the automated controls process to ensure the accuracy of the enrollment change data and will conduct assessments at the end of each term to ensure R2T4 calculations are processed correctly (estimated completion 6/30/25).
View Audit 352069 Questioned Costs: $1
Finding 551167 (2024-006)
Significant Deficiency 2024
Bastyr University
WA
Student Financial Aid Reporting
The University should take steps to ensure that its procedures to submit enrollment information to NSLDS in a timely manner are strictly followed.
The University should take steps to ensure that its procedures to submit enrollment information to NSLDS in a timely manner are strictly followed.
View Audit 352068
Finding 551166 (2024-005)
Significant Deficiency 2024
Bastyr University
WA
Student Financial Aid
The University should correct the enrollment status information in NSLDS for the students noted above. In addition, the Institution should take steps to ensure that its procedures to accurately submit information to NSLDS are strictly followed
The University should correct the enrollment status information in NSLDS for the students noted above. In addition, the Institution should take steps to ensure that its procedures to accurately submit information to NSLDS are strictly followed
View Audit 352068
Finding 551145 (2024-002)
Significant Deficiency 2024
Bergen Community College
NJ
Special Tests & Provisions Student Financial Aid Significant Deficiency
Views of Responsible Officials: The college agrees with this finding with explanation. These occurrences were anomalies related to a rare misalignment of the academic calendar for summer session for the 2023/2024 academic year. The calculation findings for five of the seven students were related to ...
Views of Responsible Officials: The college agrees with this finding with explanation. These occurrences were anomalies related to a rare misalignment of the academic calendar for summer session for the 2023/2024 academic year. The calculation findings for five of the seven students were related to a schedule misalignment for the summer semester. The academic calendar for the 2023/2024 award year had 106 days of enrollment during the summer semester. There was a gap of six days between the Summer 2 and Summer 3 terms skewed the calculations. The College has not identified a similar alignment gap for any previous award year. The Financial Aid Office will actively monitor the development of the academic calendar. Additionally, the Financial Office will review and revise existing procedures to identify areas for improvement to ensure that all withdrawn students who began attendance will have their Return to Title IV calculations accurately completed. The Financial Aid Office has taken steps to retrain relevant financial aid personnel and developed internal checks for accuracy in the calculation process.
View Audit 352065
Finding 551141 (2024-001)
Significant Deficiency 2024
Bergen Community College
NJ
Special Tests & Provisions Student Financial Aid Reporting
Views of Responsible Officials: The College has noted that this finding may not align with the unique nature of our summer session, which has three terms included. There are four non-standard summer terms that do not follow the same reporting structure as the Fall and Spring Terms. The College inter...
Views of Responsible Officials: The College has noted that this finding may not align with the unique nature of our summer session, which has three terms included. There are four non-standard summer terms that do not follow the same reporting structure as the Fall and Spring Terms. The College interprets the 60-day reporting requirement to apply to the standard terms for Fall and Spring only. Historically, the college has reported summer enrollments in August, which has been treated as compliant by the Clearinghouse. However, after further review, the College will adjust its reporting schedule to align with recommendations from this finding. This adjustment will ensure that summer reporting aligns with the 60-day timeframe that is consistent with the Fall and Spring terms.
View Audit 352065
Finding 551122 (2024-001)
Significant Deficiency 2024
Molloy College
NY
Student Financial Aid Special Tests & Provisions Reporting
Name of contact person responsible for corrective action: Marguerite Lane, Associate Vice President Enrollment Management Mlane@molloy.edu 516-323-4014 Corrective action: Molloy University understands the finding and has devised a process to ensure that the correct withdrawal dat...
Name of contact person responsible for corrective action: Marguerite Lane, Associate Vice President Enrollment Management Mlane@molloy.edu 516-323-4014 Corrective action: Molloy University understands the finding and has devised a process to ensure that the correct withdrawal date is recorded National Student Loan Data System (NSLDS) with the 60-day window from the date of determination. In the finding, the withdrawals were reported within the window, but the effective dates reported were incorrect. We identified the issue and made the corrections, but the corrections were made outside the 60-day window. To address this, we will utilize our current practice of relying on error reports to address such errors, but we will run these reports at an increased frequency (bi-weekly) and have an additional staff member review the information. We will keep a file for each student withdrawal to show that our dates align in our system, the National Student Clearinghouse, and NSLDS within the required timeframe. Proposed Completion Date: March 31, 2025
View Audit 352050
Finding 551117 (2024-001)
Material Weakness 2024
Trinity College of Florida, Inc.
FL
Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking
Trinity College of Florida will develop, implement and maintain a written information security program in accordance with GLBA compliance
Trinity College of Florida will develop, implement and maintain a written information security program in accordance with GLBA compliance
View Audit 352041
Finding 551106 (2024-014)
Material Weakness 2024
William Peace Universirty
NC
Student Financial Aid Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.303
Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University implement additional internal controls to ensure proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to separate...
Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University implement additional internal controls to ensure proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing training should be provided to financial aid staff on the importance of internal controls and compliance with Title IV regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office has expanded staffing and continues to provide ongoing training through NASFAA, NCASFAA, CFNC, and Ellucian. Roles and responsibilities are now clearly defined to ensure proper segregation of duties, and cross-training is underway to provide continuity during vacancies. These efforts support the implementation of enhanced internal controls and Title IV compliance. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: June 2025
View Audit 352022
Finding 551105 (2024-013)
Significant Deficiency 2024
William Peace Universirty
NC
Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking
Student Financial Assistance Cluster - Assistance Listing No. 84.268 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a proc...
Student Financial Assistance Cluster - Assistance Listing No. 84.268 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a process to maintain all reconciliations as support of performance monthly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Business Office will complete monthly reconciliations in addition to the reconciliation at the time of draw of federal funds to comply with federal requirements. Name(s) of the contact person(s) responsible for corrective action: Belinda Burke, VP for Finance and Administration, CFO Planned completion date for corrective action plan: April 2025
View Audit 352022
Finding 551103 (2024-012)
Significant Deficiency 2024
William Peace Universirty
NC
Student Financial Aid Reporting Significant Deficiency
Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported timely. Explanation of disagreement with audit finding: There is no...
Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Department will evaluate its policies and procedures around reporting to the COD to ensure that student information is reported timely. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: April 2025
View Audit 352022
Finding 551098 (2024-010)
Material Weakness 2024
William Peace Universirty
NC
Student Financial Aid Eligibility Material Weakness
Student Financial Assistance Cluster - Assistance Listing No. No. 84.268 Recommendation: We recommend the University review its process around sending exit counseling information to students to ensure this information is received and the University is performing required procedures. Explanation of d...
Student Financial Assistance Cluster - Assistance Listing No. No. 84.268 Recommendation: We recommend the University review its process around sending exit counseling information to students to ensure this information is received and the University is performing required procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office has hired additional staff, enhanced training efforts, and established a standard procedure to send loan exit counseling notifications to students at the end of each term, ensuring regulatory compliance. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: June 2025
View Audit 352022
Finding 551097 (2024-009)
Significant Deficiency 2024
William Peace Universirty
NC
Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties
Student Financial Assistance Cluster - Assistance Listing No. No. 84.063 Recommendation: We recommend the University implement a review process to ensure calculations of Pell awards are using the correct information. Explanation of disagreement with audit finding: There is no disagreement with the a...
Student Financial Assistance Cluster - Assistance Listing No. No. 84.063 Recommendation: We recommend the University implement a review process to ensure calculations of Pell awards are using the correct information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To reduce calculation errors in Pell Grant awards, the Financial Aid Office has hired additional staff, increased training, and implemented an automated packaging system. This system ensures Pell award amounts are calculated using accurate and verified student information. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: August 2025
View Audit 352022
Finding 551094 (2024-008)
Significant Deficiency 2024
William Peace Universirty
NC
Subrecipient Monitoring Student Financial Aid Significant Deficiency
Student Financial Assistance Cluster - Assistance Listing No. No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Explanation of disagreement with audit fin...
Student Financial Assistance Cluster - Assistance Listing No. No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Information Technology Department will ensure its written information security program addresses the required minimum elements outlined in 16 CFR 314.4. Name(s) of the contact person(s) responsible for corrective action: Belinda Burke, VP for Finance and Administration, CFO Planned completion date for corrective action plan: April 2025
View Audit 352022
Finding 551093 (2024-007)
Significant Deficiency 2024
William Peace Universirty
NC
Questioned Costs Student Financial Aid Significant Deficiency
Student Financial Assistance Cluster - Assistance Listing No. 84.268 Recommendation: We recommend the University establish additional policies to ensure all students meet the financial need criteria before awarding Title IV funds. Explanation of disagreement with audit finding: There is no disagree...
Student Financial Assistance Cluster - Assistance Listing No. 84.268 Recommendation: We recommend the University establish additional policies to ensure all students meet the financial need criteria before awarding Title IV funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office has hired additional personnel to enhance oversight and processing capacity. Staff will continue to receive training and will review all late and supplemental awards to verify that students meet financial need criteria before Title IV funds are disbursed. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: June 2025
View Audit 352022 Questioned Costs: $1
Finding 551091 (2024-006)
Significant Deficiency 2024
William Peace Universirty
NC
Reporting Student Financial Aid Significant Deficiency
Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review regulations to ensure the University understands the definitions for enrollment information required to be reported to the NSLDS. Explanation of...
Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review regulations to ensure the University understands the definitions for enrollment information required to be reported to the NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Given the findings related to enrollment reporting, the University will review policies and procedures to ensure information is reported in a timely and accurate manner. The University will review the NSLDS regulations and ensure understanding and compliance of the NSLDS definitions related to required reporting of enrollment changes. The University will verify program lengths for all active programs reported to NSLDS. The Registrar is the responsible party for enrollment reporting via NSC to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Lynda Szymanski, VP for Academic Affairs Planned completion date for corrective action plan: April 2025
View Audit 352022
Finding 551087 (2024-005)
Significant Deficiency 2024
William Peace Universirty
NC
Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking
Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University review the R2T4 requirements and ensure their process incorporates a review of students to ensure no calculations are missed that should be performed. Explanation ...
Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University review the R2T4 requirements and ensure their process incorporates a review of students to ensure no calculations are missed that should be performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: At the conclusion of each academic term, the Director of Financial Aid will review enrollment data with the Registrar’s Office to identify students who may require Return of Title IV (R2T4) calculations. Completion of all required R2T4 calculations will be documented and verified by the Director to ensure full compliance with federal guidelines. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: May 2025
View Audit 352022
Finding 548686 (2024-005)
Significant Deficiency 2024
Wilberforce University
OH
Student Financial Aid Matching / Level of Effort / Earmarking Eligibility
Management agrees with the auditors and has initiated the necessary corrective action plan to mitigate the deficiency from occuring again. The plan is to implement new procedures to ensure the reporting to the NSLDS is done on a timely basis.
Management agrees with the auditors and has initiated the necessary corrective action plan to mitigate the deficiency from occuring again. The plan is to implement new procedures to ensure the reporting to the NSLDS is done on a timely basis.
View Audit 352009
Finding 548676 (2024-004)
Significant Deficiency 2024
Stevenson University, Inc.
MD
Internal Control / Segregation of Duties Student Financial Aid Matching / Level of Effort / Earmarking
Name of Responsible Individual: Brandon Rhone, Analyst, Financial Aid Systems, and Chad Wick, Director Financial Aid Corrective Action: The Vice President of Enrollment created a process, implemented in the Spring of 2023, that automated the student loan disbursement notifications with-in the requi...
Name of Responsible Individual: Brandon Rhone, Analyst, Financial Aid Systems, and Chad Wick, Director Financial Aid Corrective Action: The Vice President of Enrollment created a process, implemented in the Spring of 2023, that automated the student loan disbursement notifications with-in the required 30 days of student accounts transmitting their loans, but some of them were already disbursed before this new process. To further enhance this process the FA Analyst created a process in Colleague to automate this process as well as allow for us to keep better records of the notifications. This new process was implemented in 2024, and the University should see results on the 2024-2025 Audit. Anticipated Completion Date: March 31, 2025
View Audit 351998
Finding 548673 (2024-005)
Significant Deficiency 2024
Stevenson University, Inc.
MD
Student Financial Aid Reporting Matching / Level of Effort / Earmarking
Name of Responsible Individual: Montague Blount, Registrar Corrective Action: The University Registrar has worked to develop and implement a plan to ensure appropriate cross-training, position backup, and a system of proper checks and balances to improve quality control and continuity in executing ...
Name of Responsible Individual: Montague Blount, Registrar Corrective Action: The University Registrar has worked to develop and implement a plan to ensure appropriate cross-training, position backup, and a system of proper checks and balances to improve quality control and continuity in executing core functions within the Registrar's Office. To enhance our efforts on this front, the University Registrar will implement additional training measures and reporting SOPs to ensure all status changes and error records are submitted to the NSC/NSLDS website within the required timeframe. These efforts will strengthen accuracy and overall compliance with reporting requirements. Enrollment reporting remains a critical focus of this initiative. Anticipated Completion Date: June 30, 2025
View Audit 351998
Finding 548670 (2024-003)
Significant Deficiency 2024
Stevenson University, Inc.
MD
Internal Control / Segregation of Duties Student Financial Aid Reporting
Name of Responsible Individual: Mary Beth Schiller-Schwenke, Chief Financial Officer and Joyce Sawyer, Director of Payroll Services Corrective Action: The instance of non-compliance occurred during a period of software change for timecard recordkeeping. The former software allowed the supervisor to...
Name of Responsible Individual: Mary Beth Schiller-Schwenke, Chief Financial Officer and Joyce Sawyer, Director of Payroll Services Corrective Action: The instance of non-compliance occurred during a period of software change for timecard recordkeeping. The former software allowed the supervisor to electronically approve a student timecard after payroll was processed. The new software does not allow this and the process now requires manual follow-up and signature. The Payroll Office in combination with Human Resources will enhance training for supervisors and require additional training for those supervisors that fail to approve timecards timely. Reporting has been improved to identify timecards that have not been approved. A procedure change has been implemented to remove wages from FWS if the hours in question remain unapproved after 30 days. Anticipated Completion Date: March 31, 2025
View Audit 351998
Finding 548668 (2024-001)
Significant Deficiency 2024
Stevenson University, Inc.
MD
Cash Management Student Financial Aid Internal Control / Segregation of Duties
Name of Responsible Individual: Mary Beth Schiller-Schwenke, Chief Financial Officer Corrective Action: The FWS Program instances were the result of retroactive award adjustments that posted subsequent to the federal draws and federal draw reconciliations. To prevent a similar error in the future, ...
Name of Responsible Individual: Mary Beth Schiller-Schwenke, Chief Financial Officer Corrective Action: The FWS Program instances were the result of retroactive award adjustments that posted subsequent to the federal draws and federal draw reconciliations. To prevent a similar error in the future, the Business Office has modified its draw recordkeeping process to require that the employees that perform the draw requests and the reconciliations review the FWS master worksheet for any pending adjustments. The Federal Pell Grant Program instances resulted from reversals of student awards. The Business Office routinely monitors the general ledger for award transactions, however, reversals of student aid awarded late in the academic term can be missed. The Financial Aid Office will be responsible to notify the Business Office when they initiate award reversals that necessitate a refund. In addition to ongoing monitoring of the related general ledger accounts, the Business Office will also create automated reporting to notify staff of the pending account balances. Anticipated Completion Date: March 31, 2025
View Audit 351998
Stevenson University, Inc.
MD
Student Financial Aid Eligibility Internal Control / Segregation of Duties
Name of Responsible Individual: Brandon Rhone, Analyst, Financial Aid Systems, and Chad Wick, Director Financial Aid Corrective Action: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring of a new Director of Financial Aid. The University tr...
Name of Responsible Individual: Brandon Rhone, Analyst, Financial Aid Systems, and Chad Wick, Director Financial Aid Corrective Action: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring of a new Director of Financial Aid. The University transitioned from a manual awarding process to an automated process after last year’s audit but not in time to change some of the 23-24 awards. In the past FSEOG funds were used to assist students to pay off balances allowing them to register for the next semester. This practice in no longer being followed beginning with the 24-25 academic year. In addition, the Financial Aid office will review all 2024-2025 FSEOG awards to ensure that FSEOG is only awarded to Pell recipients. Anticipated Completion Date: March 31, 2025
View Audit 351998
Finding 548666 (2024-006)
Significant Deficiency 2024
Stevenson University, Inc.
MD
Student Financial Aid Reporting Matching / Level of Effort / Earmarking
Name of Responsible Individual: Chad Wick, Director Financial Aid Corrective Action: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. The newly hired staff did not receive the proper training to perform th...
Name of Responsible Individual: Chad Wick, Director Financial Aid Corrective Action: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors identifying and calculating the unearned amount of Title IV assistance to be returned. The previous Financial Aid Director was terminated before the prior corrective action plan could be fully completed. New leadership, in collaboration with the Office of Information Technology, developed an automated weekly report confirming student withdrawal dates for the 24-25 academic year. The report is emailed to Financial Aid director every Friday. The Financial Aid Director reviews the report and identifies Title IV recipients. The return of Title IV funds calculation is performed for those students. Any funds required to be disbursed or returned are then processed. Anticipated Completion Date: March 31, 2025
View Audit 351998
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