Corrective Action Plans

Finding 502359 (2024-001)

Significant Deficiency 2024

The Master's University & Seminary and Subsidiary

CA

Student Financial Aid Reporting Significant Deficiency

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The R2T4 calendar has been set up and reviewed to properly align with regulations to ensure scheduled breaks are properly included for the standard programs. A second review of all R2T4 calculations will be completed ...

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The R2T4 calendar has been set up and reviewed to properly align with regulations to ensure scheduled breaks are properly included for the standard programs. A second review of all R2T4 calculations will be completed and signed off by the Director of Financial aid as part of the R2T4 process. Person Responsible for Corrective Action Plan: Kenneth Piester Anticipated Date of Completion: 09/30/2024

View Audit 324397

Finding 502078 (2024-002)

Significant Deficiency 2024

Augustana College

IL

Questioned Costs Student Financial Aid Significant Deficiency

Recommendation: We recommend that the College review their awarding procedures and implement procedures to ensure the subsidized direct loans are awarded within a students’ need. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in respon...

Recommendation: We recommend that the College review their awarding procedures and implement procedures to ensure the subsidized direct loans are awarded within a students’ need. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Augustana corrected this student’s over-award during the audit process by reallocating the loan funds from subsidized to unsubsidized. In the future, Augustana intends to develop and utilize a report that will identify students who have negative unmet need and who have a subsidized loan. Staff will review students who appear on this report and revise aid as necessary to ensure students are within their eligibility for need-based financial aid. Name of the contact person responsible for corrective action: John Cage at johncage@augustana.edu Planned completion date for corrective action plan: January 1, 2025

View Audit 324271 Questioned Costs: $1

Finding 502070 (2024-001)

Significant Deficiency 2024

Augustana College

IL

Student Financial Aid Reporting Significant Deficiency

Recommendation: We recommend the College evaluate its procedures and policies around reporting enrollment changes to NSLDS to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action t...

Recommendation: We recommend the College evaluate its procedures and policies around reporting enrollment changes to NSLDS to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Augustana intends to add a step in the withdrawal process where enrollment status updates for withdrawing students are entered into the National Student Clearinghouse directly, as opposed to waiting for the file transmission from the Student Information System. Name of the contact person responsible for corrective action: John Cage at johncage@augustana.edu Planned completion date for corrective action plan: September 30, 2024

View Audit 324271

Finding 501926 (2024-001)

Significant Deficiency 2024

Chapman University and Affiliates

CA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

As of September 2024, we will upload our grad outlier report weekly instead of monthly in order to prevent future delays. We will be reviewing the error reports after every submission to the Clearinghouse to resolve the error CE75 issue manually until the Clearinghouse and NSLDS fix error 75 on thei...

As of September 2024, we will upload our grad outlier report weekly instead of monthly in order to prevent future delays. We will be reviewing the error reports after every submission to the Clearinghouse to resolve the error CE75 issue manually until the Clearinghouse and NSLDS fix error 75 on their end, so we will not have to do this manually.

View Audit 324097

Finding 501787 (2024-001)

Significant Deficiency 2024

Augsburg University

MN

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster— Assistance Listing Nos. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreeme...

Student Financial Assistance Cluster— Assistance Listing Nos. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that 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: Student Financial Services is working with the Registrar and IT to review the current reporting system. Adjustments will be made to reporting process to ensure accurate and timely reporting of students’ enrollment status to NSLDS. Names of the contact persons responsible for corrective action: Amanda Burgess Planned completion date for corrective action plan: May 31, 2025

View Audit 323873

Finding 501682 (2024-002)

None 2024

Central Christian College of the Bible

MO

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Inaccurate and Untimely Return of Title IV Funds (R2T4): Planned Corrective Action: The Financial Aid Department corrected the current year errors by completing the R2T4s for the students identified. In addition to those corrections, a full file review was done to ensure that no other students were...

Inaccurate and Untimely Return of Title IV Funds (R2T4): Planned Corrective Action: The Financial Aid Department corrected the current year errors by completing the R2T4s for the students identified. In addition to those corrections, a full file review was done to ensure that no other students were missed. To prevent the recurrence of this issue going forward, the Financial Aid Office will pull a 0 credit hour report at the end of each module to ensure that all unofficial withdrawals are followed up on and that all R2T4s are filed in a timely manner. Persons Responsible for Corrective Action Plan: Veronica L. Hamblin, Director of Accounting Anticipated Date of Completion: The corrections for the 2023-2024 Academic year have already been completed, and the new process will be implemented by October 18, 2024 following the completion of the August online module.

View Audit 323722

Finding 501651 (2024-002)

None 2024

John Brown University and Affiliates

AR

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Inaccurate Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: To ensure that both accurate and timely enrollment reporting is transmitted to the National Student Loan Data System (NSLDS) an NSC / NSLDS enrollment confirmation process will be established and ...

Inaccurate Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: To ensure that both accurate and timely enrollment reporting is transmitted to the National Student Loan Data System (NSLDS) an NSC / NSLDS enrollment confirmation process will be established and implemented by Student Financial Services. For official withdrawals, an additional processing step will be added to the SFS Withdrawal Tracker. The Student Financial Services rep will confirm that the correct withdrawal date has been accurately reported to the National Student Clearinghouse (NSC) by the Registrar’s office and then correctly transmitted to the National Student Loan Data System (NSLDS). If the reported enrollment date does not align with the Last Date of Academic Related Activity, the SFS Representative will notify either the Director of Student Financial Services (Michelle Baker) or the Chief Student Finance Officer (David Burney) to manually adjust the dates in NSLDS. The SFS office will then notify the Registrar’s office that the dates have been manually updated. For unofficial withdrawals, if a student is identified as an unofficial withdrawal (e.g. lack of attendance in a course resulting in an R2T4 calculation being performed) once the withdrawal list has been reported at the end of each semester by the Registrar’s office, the Student Financial Services Representative will confirm that the correct withdrawal date has been accurately reported to the National Student Clearinghouse (NSC) by the Registrar’s office and then correctly transmitted to the National Student Loan Data System (NSLDS). If the reported enrollment date does not align with the Last Date of Academic Related Activity, the SFS Representative will notify either the Director of Student Financial Services (Michelle Baker) or the Chief Student Finance Officer (David Burney) to manually adjust the dates in NSLDS. The SFS office will then notify the Registrar’s office that the dates have been manually updated. Person Responsible for Corrective Action Plan: David Burney, Chief Student Finance Officer Anticipated Date of Completion: Implementation of process will begin 9/30/2024

View Audit 323688

Finding 501649 (2024-001)

None 2024

John Brown University and Affiliates

AR

Student Financial Aid Reporting

Untimely and Inaccurate Returns of Title IV Funds (R2T4) Planned Corrective Action: In addition to the Withdrawal Tracker created last year to document the withdrawal process and communicate across the department, the SFS team will now also pull official withdrawal lists (including unofficial withdr...

Untimely and Inaccurate Returns of Title IV Funds (R2T4) Planned Corrective Action: In addition to the Withdrawal Tracker created last year to document the withdrawal process and communicate across the department, the SFS team will now also pull official withdrawal lists (including unofficial withdrawals) every semester with assistance from the Director of Institutional Research and Assessment –Lynette Duncan. We will also work with her to create a report which will pull that data directly from Colleague SIS rather than relying on communication from the registrar’s office or professor. We have several new arrangements that will improve our R2T4 processes and ensure accuracy. Firstly, the registrar’s office has created a new automated withdrawal form detailing all elements pertaining to LDA dates that will produce automated email notifications to our office. This form will pull data from BlackBoard listing the last interaction date the student had with the BB system. This will encourage our tracking processes to run more swiftly. In addition, we will still track each withdrawal in real time on the SFS Withdrawal Tracker, but the information will be cross-referenced against the system generated withdrawal data from the Director of Institutional Research and Assessment to ensure precision and compliance. After the Director of Student Financial Services processes an R2T4 calculation, the Chief Student Finance Officer will review the work to ensure accuracy on a weekly basis. Finally, we will move the R2T4 process into Colleague rather than doing this process on the COD website. This will add another layer of checks and balances for correct data and greatly increase the speed with which the Director of Student Financial Services can perform R2T4s. Person Responsible for Corrective Action Plan: Michelle Baker McFadden, Director of Student Financial Services Anticipated Date of Completion: Implementation of process will begin 9/30/2024

View Audit 323688

Finding 501570 (2024-001)

Significant Deficiency 2024

Florida Institute of Technology, Inc.

FL

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid

Student financial aid programs cluster Significant Deficiency in Internal Control Condition: During our testing of the regulations, one student who was identified as a withdrawn student did not have the proper calculation performed to determine if funds should be returned in accordance with the ...

Student financial aid programs cluster Significant Deficiency in Internal Control Condition: During our testing of the regulations, one student who was identified as a withdrawn student did not have the proper calculation performed to determine if funds should be returned in accordance with the regulations. Auditor Recommendations: The University should continue to update processes and procedures to ensure compliance in the future. These updated processes should include adequate segregation of duties and review steps to ensure that all students who are subject to potential recapture and return of funds are analyzed in the time frame dictated by the CFR. Action Taken: A new weekly quality assurance report has been created that identifies all withdrawn students. It identifies any student that requires a return calculation in the financial aid management system, and that all required Title IV aid has been returned. The report is generated and reviewed by both the Associate Director and Assistant Director of Financial Aid to ensure adequate segregation of duties and review. This report was run for the entirely of fiscal year 2024 and no other returns were found to be outstanding.

View Audit 323625

Finding 501244 (2024-002)

Significant Deficiency 2024

The Corporation of Gonzaga University

WA

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

FINDING 2024‐002 – Special Tests and Provisions – Return of Title IV (R2T4) Funds Significant Deficiency in Internal Control over Compliance Recommendation: The University should design and implement a robust review process of all R2T4 calculations for official and unofficial withdrawals. This will ...

FINDING 2024‐002 – Special Tests and Provisions – Return of Title IV (R2T4) Funds Significant Deficiency in Internal Control over Compliance Recommendation: The University should design and implement a robust review process of all R2T4 calculations for official and unofficial withdrawals. This will help ensure the accuracy of the calculation before the return of funding. Response: There is no disagreement with this audit finding. Action taken in response to finding: To ensure the accuracy of R2T4 calculations, the Student Financial Services Office will take the following actions: • Implementation of R2T4 Module: Starting with the 2024-2025 academic year, the Financial Aid Office will utilize the Banner-delivered R2T4 module to perform calculations, ensuring more accurate and consistent data management. • Multi-Step Review Process: A multi-step review process has been implemented by Student Financial Services staff to ensure thorough verification of all R2T4 calculations and timely returns of funds. • Enhanced Training: Staff are pursuing additional training on R2T4 regulations and procedures to further strengthen their expertise and reduce the risk of future discrepancies. These actions are in process currently, and expected to be fully implemented and corrected by October 2024 to ensure that R2T4 calculations are prepared and reviewed for accuracy for the 2024-2025 award year. Enhanced training will continue on a go forward basis. Contact Person(s): Louisa Diana, Director of Compliance; Sarah Everitt, Dean of Student Financial Services;

View Audit 323529

Finding 501237 (2024-001)

Significant Deficiency 2024

The Corporation of Gonzaga University

WA

Student Financial Aid Reporting Significant Deficiency

FINDING 2024‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a policy to ensure graduates for all semesters/terms are reported timely. Response: There is no disagreement with this aud...

FINDING 2024‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a policy to ensure graduates for all semesters/terms are reported timely. Response: There is no disagreement with this audit finding. Action taken in response to finding: Upon identifying this deficiency, Gonzaga University immediately updated its enrollment reporting schedules to ensure timely reporting of mid-summer conferrals. Going forward, all mid-summer degree conferrals will be reported within the required federal timeframe to maintain compliance with Title IV regulations. This adjustment guarantees accurate and timely data submission to the National Student Loan Data System (NSLDS), preventing future delays or discrepancies in reporting. Our new schedule has 9 reporting dates for degree transmission and 14 reporting dates for enrollment transmission in a calendar year. The increased frequency ensures compliance with the 60-day threshold and guarantee that no student will be reported outside the 60-day threshold. We consider this to be remediated. Contact Person(s): Sarah Everitt, Dean of Student Financial Services; Maxwell Kwenda, University Registrar & Director of Institutional Research

View Audit 323529

Finding 501172 (2024-006)

Significant Deficiency 2024

Virginia Union University

VA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Criteria: Under the Pell grant and ED loan programs, Institutions are responsible for timely enrollment reporting to NSLDS whether they report directly or via a third-party servicer such as the National Student Clearinghouse (NSC). Enrollment Reporting in a timely and accurate manner is critical for...

Criteria: Under the Pell grant and ED loan programs, Institutions are responsible for timely enrollment reporting to NSLDS whether they report directly or via a third-party servicer such as the National Student Clearinghouse (NSC). Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 60 days whenever the enrollment status changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absences. The University concurs with the audit finding and will adhere to the corrective action plan. Corrective Action Plan: Viginia Union University has signficiantly imprved its compliance with federal regulations for enrollment reporting to the National Student Loan Data System (NSLDS). During FY24, a comprehensive review of all files from FY21 to FY23 was conduted to ensure accurate and timely reporting of students' enrollment statuses to the NSLDS. In addition to reviewing previous years, any delinquent reporting for FY24 was also updated to reflect the current status. By April 2024, reporting to NSLDS was synched to a cycle to ensure compliance with the 60-day window. In October 2023, Virginia Union revised its Enrollment Reporting Policy to outline the reporting schedule for submissions to the National Student Clearinghouse (NSC). This updated policy sets forth the timeline and guidelines for enrollment reporting. In addition, Virginia Union University implemented a process to code students who are identified as Unofficial Withdrawal in teh Jenzabar system. This process will ensure these students are included in the monthly reporting to the National Student Clearinghouse even if they do not complete the formal withdrawal process. Responsible person(s): Doreen Dixon, Registrar, ddixon@vuu.edu, 804-257-5845. Robert Merino, Executive Director of Financial Aid, jrmerino@vuu.edu, 804-254-3973. Planned Date of Completion of Corrective Action: August 31, 2024.

View Audit 323427

Finding 499625 (2024-001)

Significant Deficiency 2024

University of Saint Francis

IN

Questioned Costs Student Financial Aid Special Tests & Provisions

We will implement the following solutions immediately to help mitigate our R2T4 processes: the Business Office (BO) will submit refunds to the Department of Education (DOE) as separate transactions rather than netting them with drawdowns; Financial Aid (FA) will confirm correct withdrawal date befor...

We will implement the following solutions immediately to help mitigate our R2T4 processes: the Business Office (BO) will submit refunds to the Department of Education (DOE) as separate transactions rather than netting them with drawdowns; Financial Aid (FA) will confirm correct withdrawal date before starting R2T4 processes and the BO will also confirm after FA has completed these processes; and the BO will save the Student Complete Withdrawal Form, R2T4 Workflow item, ROFC screenshot, FATP email and file from FA, Student Statement, G5/G6 screenshot and email confirmation of refund

View Audit 322507 Questioned Costs: $1

Finding 498829 (2024-001)

Significant Deficiency 2024

Brescia University Inc.

KY

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Students’ information is submitted by the Clearinghouse to NSLDS based on a report generated from the University’s Student Information System database. Due to significant database software changes, the report no longer included all of the information required on a student who had withdrawn. The Un...

Students’ information is submitted by the Clearinghouse to NSLDS based on a report generated from the University’s Student Information System database. Due to significant database software changes, the report no longer included all of the information required on a student who had withdrawn. The University has identified the error with the report and has created a new database report that includes all of the required information, including for students who have withdrawn. The new database report will be submitted to the Clearinghouse and to NSLDS. Student information, including social security numbers, is submitted to the Clearinghouse based on reports from the University’s Student Information System database. To prevent submitting batches with incorrect social security numbers, the Registrar’s Office will provide a report of student information to the Financial Aid Office prior to submitting batches to the Clearinghouse. The Financial Aid Office will verify the SIS data with the Financial Aid database, and report any discrepancies to the Registrar’s Office for correction, prior to the batch submission.

View Audit 321580

Finding 498233 (2024-002)

Material Weakness 2024

Denmark Technical College

SC

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Enrollment Reporting Corrective Action Plan: The Office of the Registrar will lead the implementation of new internal controls to ensure all enrollment status changes are reviewed and submitted in a timely manner in accordance with federal requirements. Specifically, measures will be taken to me...

Enrollment Reporting Corrective Action Plan: The Office of the Registrar will lead the implementation of new internal controls to ensure all enrollment status changes are reviewed and submitted in a timely manner in accordance with federal requirements. Specifically, measures will be taken to meet the Title IV requirement that the College completes and reports within a minimum of 60 days all student status changes to the National Student Loan Data System (NSLDS). Anticipated Completion Date: Fiscal Year 2025. Name of Contact Person Responsible for the Corrective Action Plan: Rashad Rogers

View Audit 320975

Finding 498228 (2024-001)

Material Weakness 2024

Denmark Technical College

SC

Student Financial Aid Allowable Costs / Cost Principles

Return of Title IV Funds Corrective Action Plan: The College Financial Aid Office and Business Office will implement new internal controls and procedures to ensure all student Title IV calculations are calculated correctly, reviewed in a timely manner, and ensure funds are returned promptly. Dea...

Return of Title IV Funds Corrective Action Plan: The College Financial Aid Office and Business Office will implement new internal controls and procedures to ensure all student Title IV calculations are calculated correctly, reviewed in a timely manner, and ensure funds are returned promptly. Deadlines have been created to submit student withdrawals timely to the Financial Aid Department. A monthly reconciliation between the Registrar and Financial Aid Office will ensure withdrawals and correct withdrawal dates are reported to the Financial Aid Office in a timely manner. The Business Office will review the Financial Aid Office's calculation of funds for accuracy to ensure the correct amount is returned to the Department of Education. Anticipated Completion Date: Fiscal year 2025. Name of Contact Person Responsible for the Corrective Action Plan: Rashad Rogers

View Audit 320975

Finding 497631 (2024-001)

Significant Deficiency 2024

Howard Payne University

TX

Questioned Costs Student Financial Aid Significant Deficiency

Incorrect Return of Title IV Funds Calculation Planned Corrective Action: Extensive training on module (Summer, Summer 1, and Summer 2) refunds have been completed. Each summer refresher training will take place due to the complicated nature of summer module calculation. Students who complete FA...

Incorrect Return of Title IV Funds Calculation Planned Corrective Action: Extensive training on module (Summer, Summer 1, and Summer 2) refunds have been completed. Each summer refresher training will take place due to the complicated nature of summer module calculation. Students who complete FAFSA after a term will be reviewed to determine how much Title IV aid they are eligible to have disbursed. The R2T4 calculation will be processed to learn the percentage earned. Exception to the R2T4 will be if student completed the module/term successfully. Person Responsible for Corrective Action Plan: Karen LaQuey, Director of Student Financial Aid Anticipated Date of Completion: Immediately

View Audit 320424 Questioned Costs: $1

Finding 497446 (2024-001)

None 2024

William Carey University

MS

Special Tests & Provisions Student Financial Aid Reporting

The University respectfully submits the following corrective action plan. Audit Period: June 30, 2024. The finding discussed below is numbered consistently with the number assigned in the schedule of findings and questioned costs. Corrective Action Plan for Federal Awards Findings and Questioned Cos...

The University respectfully submits the following corrective action plan. Audit Period: June 30, 2024. The finding discussed below is numbered consistently with the number assigned in the schedule of findings and questioned costs. Corrective Action Plan for Federal Awards Findings and Questioned Costs. 2024-001 Special Tests and Provisions - Enrollment Reporting. As a result of the delayed NSLDS enrollment reporting and subsequent finding, William Carey University has implemented the following measures to ensure timely future reporting. 1. Any difficulties in federal reporting, technical or otherwise, will be reported to the area vice president and to the CFO promptly. 2. Any difficulties in federal reporting, technical or otherwise, will be reported to the federal agency promptly for purposes of notification, to seek guidance regarding possible alternative reporting methods, and/or to request extension to the reporting period. 3. All documentation and communication regarding the reporting difficulty will be kept by the responsible department director and submitted to the CFO. The offices of Academic Affairs and Business Affairs will cooperate to ensure immediate implementation. Name of Responsible Person: Grant Guthrie, Vice President and Chief Financial Officer. Expected Date of Completion: Current.

View Audit 320239

Finding 486104 (2024-002)

Significant Deficiency 2024

Abilene Christian University

TX

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

Responsible Individual: Tamara Long Vice President for Enrollment and Student Engagement Abilene Christian University Finding 2024-002 Special Tests & Provisions - Bonus & Incentives Related to Enrollment Agency Name: U.S. Deparlment of Education Program Name: Federal Pell Grant, Federal Direct Stud...

Responsible Individual: Tamara Long Vice President for Enrollment and Student Engagement Abilene Christian University Finding 2024-002 Special Tests & Provisions - Bonus & Incentives Related to Enrollment Agency Name: U.S. Deparlment of Education Program Name: Federal Pell Grant, Federal Direct Student Loans, SEOG, Federal Work Study and TEACH Grants August 19, 2024 Finding Summary: Incentive Compensation (34 CFR 668.14(b)(22)(i) Institutions are required, within the Program Participation Agreement (PPA), to acknowledge that they will not provide any commission, bonus, or other incentive payment based on any part, directly or indirectly, upon success in securing enrollments or awards of financial aid. The university documented several bonus payments to individuals related to enrollment strategies and goals. Corrective Action Plan (CAP): Based on the findings of the Special Tests and Provisions for Incentive Compensation as part of (34 CFR668.14(b)(22}(i), the offices of enrollment and financial operations have identified additional review and controls that will be put in place to mitigate future risk of non-compliance. Additional review will be required by a financial operations member for any requests made for enrollment related staff. In addition, a formal tenure bonus structure has already been put in place to ensure that no bonuses or incentives are given based on enrollment goals. Anticipated Completion Date: As the tenured bonus structure has already been activated, the review of bonuses raises, and incentive pay will immediately be required to go through an additional financial review for compliance. The anticipated completion date is July 1, 2024

View Audit 318751 Questioned Costs: $1

Finding 486102 (2024-001)

Significant Deficiency 2024

Abilene Christian University

TX

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Responsible Individual: Eric Gumm Registrar and Director of First Year Program and Academic Development Center Abilene Christian University Finding 2024-001 concerning Enrollment Reporting Agency Name: U.S. Department of Education Program Name: Federal Pell Grant, Federal Direct Student Loans August...

Responsible Individual: Eric Gumm Registrar and Director of First Year Program and Academic Development Center Abilene Christian University Finding 2024-001 concerning Enrollment Reporting Agency Name: U.S. Department of Education Program Name: Federal Pell Grant, Federal Direct Student Loans August 19, 2024 Finding Summary: Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309) Institutions are required to report enrollment information. The University's processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Out of the population of 829 students with student attendance changes required to be reported, a sample of 25 students were selected for testing. The University failed to report 3 students who had changes in enrollment status. Of the three students the University failed to report, 2 students had withdrawn from the University. The University reported the incorrect enrollment effective dates for 3 students at the program and campus levels. The University failed to report graduated status for 2 students (students were reported as withdrawn and the University failed to subsequently update the status to graduated). The University reported the incorrect Program Enrollment Effective Date for 1 student. The University did not report a change in enrollment status in a timely manner for 1 student. Corrective Action Plan (CAP): Based on the findings within the Federal and State Financial Assistance Program audit, it was determined that a significant deficiency exists within the review of reporting for student enrollment through the National Student Loan Data System (NSLDS). The office of Student Financial Services has identified the need for regular reconciliation of updates to student enrollment status from the Banner point of record to the NSLDS system. Our plan of action begins with a comprehensive understanding of the roles and responsibilities between the financial aid office and the registrar's office. Once this is well documented, the Office of the Registrar will begin a monthly reconciliation of enrollment reporting for any student status changes that have happened within that month. Anticipated Completion Date: The timeline for this CAP begins with the formal documentation of the enrollment reporting process. This will take place prior to the start of the Fall 2024 semester. The reconciliation of reporting will begin in September 2024 after 12th day of enrollment is confirmed and sent to the Clearinghouse for updates. The anticipated completion date is July 1, 2024

View Audit 318751

Finding 485406 (2024-002)

None 2024

Lincoln Christian University

IL

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

2024-002 Student Financial Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grant Program, 84.033 – Federal Work-Study Program Recommendation: We recommend the review process for awarding be documented and retain...

2024-002 Student Financial Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grant Program, 84.033 – Federal Work-Study Program Recommendation: We recommend the review process for awarding be documented and retained as support for the review and approval process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid will document each change to an award by printing a new award offer and saving to document tracking. As this is the final year in which Lincoln Christian University will have academic operations, we believe this corrective action to be sufficient for the remainder of the year. Name of the contact person responsible for corrective action: Margie Martin, Director of Accounting Planned completion date for corrective action plan: May 31, 2024.

View Audit 318153

Finding 485172 (2024-002)

Significant Deficiency 2024

Regis University

CO

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Finding 2024-002 Personnel Responsible for Corrective Action: Cathy Gorrell, Registrar Anticipated Completion Date: September 30, 2024 Corrective Action Plan: The Office of the Registrar recognizes the systematic programming of a pseudo academic program after a pseudo course has been added with a ...

Finding 2024-002 Personnel Responsible for Corrective Action: Cathy Gorrell, Registrar Anticipated Completion Date: September 30, 2024 Corrective Action Plan: The Office of the Registrar recognizes the systematic programming of a pseudo academic program after a pseudo course has been added with a future date after the student’s current program has been inactivated or graduated. This process has been at the request of the Office of Student Accounts for the graduation fee. The Office of the Registrar will work with the Office of Student Accounts to move to the system Graduation Application process rather than the customized and manual process of pseudo courses. Further, the Office of the Registrar has increased its data quality checks on the pseudo programs and courses. In conjunction, this should eliminate the reporting of active programs when the student has graduated.

View Audit 317977

Finding 1164633 (2023-003)

Material Weakness 2023

Net Treatment Services, Inc. D/b/a Net Community Care

PA

Questioned Costs Student Financial Aid Cash Management

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Foster Care Title IV-E & Stephanie Tubbs Jones Child Welfare Services Program Assistance Listing Numbers: 93.658 & 93.645 Federal Award Identification Number and Year: 21-20016 (2023) & 21-20017 (2023) Award Period: J...

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Foster Care Title IV-E & Stephanie Tubbs Jones Child Welfare Services Program Assistance Listing Numbers: 93.658 & 93.645 Federal Award Identification Number and Year: 21-20016 (2023) & 21-20017 (2023) Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance and Cash Management Recommendation: We recommend that management ensure that all invoices are based on actual expenses incurred and that there is a review an approval process of invoices before submission. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Aciton take in response to finding: Management has implemented a policy which requires each invoice to be based only on actual expenses incurred for the period and prohibits the use of a straight-line calculation to draw down funds. Invoices are also approved by the CFO prior to submission for reimbursement. Name of contact person responsible for corrective action: Regan Kelly, CEO of NorthEast Treatment Cetners, Inc. (215) 451-7000 Planned completion date for corrective action plan: January 31, 2024

View Audit 374235 Questioned Costs: $1

Finding 1160846 (2023-008)

Material Weakness 2023

Richland Community College

IL

Student Financial Aid

2023-008 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Pell Grant Program (d) Federal Direct Student Loans, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: ...

2023-008 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Pell Grant Program (d) Federal Direct Student Loans, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: The College incorrectly reported tuition and fees on the Fiscal Operations Report and Application to Participate (FISAP) for the 2021-2022 academic year. We consider this to be an instance of noncompliance of the Reporting compliance requirement and is a repeated finding shown in Section IV of this report as prior year finding 2022-004. Statistical sampling was not used in making sample selections. Corrective Action Plan: The responsible parties listed below will thoroughly review all FISAP reporting requirements and necessary data elements prior to FISAP submission to ensure accuracy. Responsible Party for Corrective Action Plan: Director of Financial Aid and Veteran Affairs, Controller, Vice President of Financial Services Implementation Date for Correction Action Plan: Correction to FISAP will be submitted as soon as the amount of tuition and fees is confirmed by the Controller or Vice President of Financial Services. By September 2025 to accurately report the amount of tuition and fees on the upcoming FISAP reporting cycle due by September 30, 2025.

View Audit 370935

Finding 1160842 (2023-007)

Material Weakness 2023

Richland Community College

IL

Student Financial Aid Reporting Special Tests & Provisions

2023-007 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Pell Grant Program (d) Federal Direct Student Loans, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: ...

2023-007 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Pell Grant Program (d) Federal Direct Student Loans, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: The College did not report timely or accurately enrollment status changes for twelve of the forty students tested (30%). We consider this condition to be a material weakness for the Special Tests and Provisions compliance requirement and is a repeated finding shown in Section IV of this report as prior year finding 2022-003. Statistical sampling was not used in making sample selections. Corrective Action Plan: Richland Community College adjusted our internal procedures to send enrollment reporting files on a monthly basis instead of a semester basis during the Fall 2022 semester; however, issues still persist. The campus Registrar has routinely worked with the Administrative Information Systems (AIS) Department and the National Student Clearinghouse to identify the issues related to enrollment reporting. The responsible parties listed below will conduct a review of current enrollment reporting workflows to ensure consistent and timely updates. The responsible parties listed below will explore improvements in automation through the utilization of the National Student Clearinghouse and a campus-wise transition to the Jenzabar One platform to assist with timeliness and accuracy of reporting. Due to transition in staffing, the responsible parties listed below will provide targeted training on NSLDS enrollment reporting requirements, including the expectations of timeliness and accuracy. The responsible parties will develop a secondary review to identify missed or delayed updates and take corrective action promptly. Responsible Party for Corrective Action Plan: Director of Financial Aid and Veteran Affairs, Executive Dean of Student Success (until the role of Director of Admission and Registration is filled), Administrative Information Systems (AIS) Implementation Date for Correction Action Plan: As soon as possible since enrollment reporting is completed on a monthly basis.

View Audit 370935

Corrective Action Plans

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