Corrective Action Plans

Finding 563931 (2023-013)

Significant Deficiency 2023

Barclay College

KS

Student Financial Aid Cash Management

Cash Management Planned Corrective Action: The reconciliation process will be reviewed and any deficiencies will be corrected to assure funding is drawn and disbursed within three days of receipt. Student disbursement reports will be reviewed to determine drawdown amounts before making draws from G5...

Cash Management Planned Corrective Action: The reconciliation process will be reviewed and any deficiencies will be corrected to assure funding is drawn and disbursed within three days of receipt. Student disbursement reports will be reviewed to determine drawdown amounts before making draws from G5. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

View Audit 358096

Finding 563922 (2023-011)

Material Weakness 2023

Barclay College

KS

Student Financial Aid Material Weakness

Return of Title IV (R2T4) Planned Corrective Action: A process will be implemented to run a 0-credit report at the end of each semester. This will ensure withdrawals are followed up on and that R2T4s are completed timely, if required. A process will be implanted to track student attendance in class...

Return of Title IV (R2T4) Planned Corrective Action: A process will be implemented to run a 0-credit report at the end of each semester. This will ensure withdrawals are followed up on and that R2T4s are completed timely, if required. A process will be implanted to track student attendance in classes. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

View Audit 358096

Finding 563920 (2023-010)

Material Weakness 2023

Barclay College

KS

Reporting Student Financial Aid Subrecipient Monitoring

Common Origination and Disbursement (COD) Reporting and Reconciliations Planned Corrective Action: Procedures will be implemented to monthly reconcile FDL and Pell disbursements to student accounts with disbursements reported to COD. Person Responsible for Corrective Action Plan: Lee Anders, Vice Pr...

Common Origination and Disbursement (COD) Reporting and Reconciliations Planned Corrective Action: Procedures will be implemented to monthly reconcile FDL and Pell disbursements to student accounts with disbursements reported to COD. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

View Audit 358096

Finding 563919 (2023-009)

Material Weakness 2023

Barclay College

KS

Questioned Costs Student Financial Aid Eligibility

Incorrect Pell Calculations Planned Corrective Action: A process will be implemented to verify Pell is correctly awarded before disbursements are made. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

View Audit 358096 Questioned Costs: $1

Finding 563918 (2023-008)

Material Weakness 2023

Barclay College

KS

Questioned Costs Student Financial Aid Material Weakness

Need Analysis Planned Corrective Action: All scholarships will be marked as estimated financial assistance and an awarding check for need will be done accurately before final distribution. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Da...

Need Analysis Planned Corrective Action: All scholarships will be marked as estimated financial assistance and an awarding check for need will be done accurately before final distribution. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

View Audit 358096 Questioned Costs: $1

Finding 563916 (2023-007)

Material Weakness 2023

Barclay College

KS

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Enrollment Reporting to NSLDS Planned Corrective Action: A process will be created to ensure enrollment is reported timely and accurately. Spot checks of NSLDS will be performed on enrollment status throughout the year. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for B...

Enrollment Reporting to NSLDS Planned Corrective Action: A process will be created to ensure enrollment is reported timely and accurately. Spot checks of NSLDS will be performed on enrollment status throughout the year. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

View Audit 358096

Finding 563911 (2023-006)

Material Weakness 2023

Barclay College

KS

Student Financial Aid Eligibility Material Weakness

ISIR Comment Resolution Planned Corrective Action: All ISIR comment codes will be resolved before disbursement of federal aid to students. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

View Audit 358096

Finding 563906 (2023-005)

Material Weakness 2023

Barclay College

KS

Eligibility Student Financial Aid Material Weakness

Satisfactory Academic Progress Planned Corrective Action: The SAP policy will be reviewed or created as needed and a procedure will be implemented based on that policy. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09...

Satisfactory Academic Progress Planned Corrective Action: The SAP policy will be reviewed or created as needed and a procedure will be implemented based on that policy. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

View Audit 358096

Finding 563901 (2023-004)

Material Weakness 2023

Barclay College

KS

Student Financial Aid Material Weakness

Lack of Administrative Capability Planned Corrective Action: The financial aid officer will participate in trainings specific to knowledge gaps. In addition, monthly entries will be made in the general ledger for financial aid activity and monthly balances will be reconciled between the general ledg...

Lack of Administrative Capability Planned Corrective Action: The financial aid officer will participate in trainings specific to knowledge gaps. In addition, monthly entries will be made in the general ledger for financial aid activity and monthly balances will be reconciled between the general ledger and financial aid software. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

View Audit 358096

Finding 561616 (2023-006)

Significant Deficiency 2023

Ramsey County

MN

Internal Control / Segregation of Duties Student Financial Aid Eligibility § 200.303

Finding Number: 2023-006 Finding Title: Reporting – DHS Social Service Fund (DHS-2556) Program: 93.658 Foster Care – Title IV-E Name of Contact Person Responsible for Corrective Action: Janelle White – Controller for Ramsey County’s Health & Wellness Service Team Enrique Rivera – Fiscal Services ...

Finding Number: 2023-006 Finding Title: Reporting – DHS Social Service Fund (DHS-2556) Program: 93.658 Foster Care – Title IV-E Name of Contact Person Responsible for Corrective Action: Janelle White – Controller for Ramsey County’s Health & Wellness Service Team Enrique Rivera – Fiscal Services Manager for Ramsey County’s Health & Wellness Service Team Corrective Action Planned: Starting in the third quarter of 2024, Ramsey County instituted an additional verification step in the review process to support the determination of accurate cost pool categorization of reimbursable costs for the Random Moment Time Study Reports cost reports. The additional step will be to confirm that on the Summary Tab of the Quarterly Payroll file, the cost codes lines are in sequential order and that the corresponding expense totals match the cost code. The Senior Accountant will do the first review of this step, and the Fiscal Manager will complete the second review. The error on the 2nd quarter 2023 report was remedied and resubmitted in the 2nd quarter of 2024. Anticipated Completion Date: July of 2024 when the 2nd quarter DHS-2556 and DHS 2550 are due to be complete and finalized.

View Audit 357223

Finding 555631 (2023-012)

None 2023

Sullivan County Community College

NY

Student Financial Aid Matching / Level of Effort / Earmarking

The College will develop and followed detailed controls over grants, federal requirements accomplished by 6‐1‐2025.

View Audit 354200

Finding 555628 (2023-009)

Significant Deficiency 2023

Sullivan County Community College

NY

Student Financial Aid Matching / Level of Effort / Earmarking

The College will continue to liquidate Perkins loans and verify all information received from the loan servicer is accurate. A reconcile of the information will be reviewed upon receiving this information from the loan servicer. This will be accomplished by 8/31/24.

View Audit 354200

Finding 555315 (2023-004)

Significant Deficiency 2023

Buffalo County

WI

Procurement, Suspension & Debarment Student Financial Aid Reporting § 200.512

CORRECTIVE ACTION PLAN (CAP): Planned Corrective Action: The County is developing policies and procedures to ensure that financial records are maintained on a more current basis, reconciled timely and audited within nine months after year-end. Anticipated Completion Date: Immediately Responsible Off...

CORRECTIVE ACTION PLAN (CAP): Planned Corrective Action: The County is developing policies and procedures to ensure that financial records are maintained on a more current basis, reconciled timely and audited within nine months after year-end. Anticipated Completion Date: Immediately Responsible Official: Lee Engfer, Administrative Coordinator

View Audit 353947

Finding 544092 (2023-001)

Significant Deficiency 2023

Quinnipiac University

CT

Procurement, Suspension & Debarment Student Financial Aid Cash Management

Uniform Guidance Corrective Action Plan Year ended June 30, 2023 Federal Finding #2023-001 Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education as soon as possible, bu...

Uniform Guidance Corrective Action Plan Year ended June 30, 2023 Federal Finding #2023-001 Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines the student withdrew. Quinnipiac University agrees with the finding. For one student who withdrew during the 2022 – 2023 academic year, the Pell funds awarded to that student were not returned to the student financial assistance account within 45 days after the University determined the student withdrew. As a result of this finding, Management has implemented additional steps within the reconciliation process of Title IV awards in order to prioritize the return of any unearned Title IV awards so that they are remitted to the student financial assistance account in a timely manner. If the Office of Management and Budget have questions regarding this plan, please reach out to Stephen Allegretto, the Associate Vice President for Finance and Controller, who is responsible for ensuring this corrective action plan is implemented, at 203-582-7962.

View Audit 350900

Finding 529876 (2023-003)

Significant Deficiency 2023

Manor College

PA

Student Financial Aid Reporting Significant Deficiency

In conjunction with the overall implementation and enhancement of financial processes and procedures to enhance financial reporting, the month-end reporting process will ensure that the financial aid and financial accounting systems are reconciled. The monthly reconciliation process and a review pro...

In conjunction with the overall implementation and enhancement of financial processes and procedures to enhance financial reporting, the month-end reporting process will ensure that the financial aid and financial accounting systems are reconciled. The monthly reconciliation process and a review process by proper Manor personnel prior to submission of the FISAP will minimize the risk of errors in the FISAP report and will assist tracking of student financial aid for each respective student receiving financial aid.

View Audit 347913

Finding 528850 (2023-009)

Material Weakness 2023

Iliff School of Theology

CO

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

Condition: The School does not have evidence that exit counseling was provided to students who withdrew or graduated as required by 34 CFR 682.604. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student ai...

Condition: The School does not have evidence that exit counseling was provided to students who withdrew or graduated as required by 34 CFR 682.604. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school has also ensured that this third-party processor is properly coordinated with the registrar’s office to meet federal requirements for exit counseling when status changes are processed. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

View Audit 346899

Finding 528848 (2023-007)

Material Weakness 2023

Iliff School of Theology

CO

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

Condition: The School does not have a documented Direct Loan quality assurance program. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school will coordinate with this third-party...

Condition: The School does not have a documented Direct Loan quality assurance program. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school will coordinate with this third-party processor to ensure that there is a documented quality assurance program that is regularly exercised for compliance purposes. All documentation will be maintained. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

View Audit 346899

Finding 528847 (2023-006)

Material Weakness 2023

Iliff School of Theology

CO

Questioned Costs Student Financial Aid Material Weakness

Condition: Our audit procedures identified an instance where the School could not locate evidence that the required R2T4 calculation under federal regulation was completed and another instance whereas the calculation was inaccurate. Planned Corrective Action: The Iliff School of Theology has contr...

Condition: Our audit procedures identified an instance where the School could not locate evidence that the required R2T4 calculation under federal regulation was completed and another instance whereas the calculation was inaccurate. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. This third-party processor is adequately skilled to complete Return of Title IV calculations and includes an established review process for quality control. All documentation will be maintained. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

View Audit 346899 Questioned Costs: $1

Finding 528846 (2023-005)

Material Weakness 2023

Iliff School of Theology

CO

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

Condition: The School does not reconcile institutional records with Direct Loan funds received from the Secretary of the U.S. Department of Education and the Direct Loan disbursement records submitted to and accepted by the Secretary of the U.S. Department of Education. Planned Corrective Action: T...

Condition: The School does not reconcile institutional records with Direct Loan funds received from the Secretary of the U.S. Department of Education and the Direct Loan disbursement records submitted to and accepted by the Secretary of the U.S. Department of Education. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs who will ensure that direct loan reconciliations are conducted on a monthly basis in coordination with the business office. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

View Audit 346899

Finding 528843 (2023-002)

Material Weakness 2023

Iliff School of Theology

CO

Student Financial Aid Reporting Material Weakness

Condition: Our audit procedures identified instances of inaccurate or untimely reporting of enrollment information to NSLDS. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school ...

Condition: Our audit procedures identified instances of inaccurate or untimely reporting of enrollment information to NSLDS. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school has also ensured that this third-party processor is properly coordinated with the registrar’s office to meet federal requirements for NSLDS enrollment reporting. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

View Audit 346899

Finding 528840 (2023-004)

Material Weakness 2023

Iliff School of Theology

CO

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

Condition: The School submitted a FISAP to the U.S. Department of Education that reported inaccurate information in several data fields within the report. In addition, there was no evidence that an individual other than the preparer reviewed the report. Planned Corrective Action: The Iliff School o...

Condition: The School submitted a FISAP to the U.S. Department of Education that reported inaccurate information in several data fields within the report. In addition, there was no evidence that an individual other than the preparer reviewed the report. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. Preparation and submission of the FISAP will be completed with coordination between the VP of Business and the third-party processor. This includes a quality review process for accuracy. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

View Audit 346899

Finding 528839 (2023-003)

Material Weakness 2023

Iliff School of Theology

CO

Student Financial Aid Material Weakness Internal Control / Segregation of Duties

Condition: Due to the limited number of personnel within the Financial Aid Department, the director of financial aid is solely responsible for packaging, awarding, and disbursing to student accounts Federal Student Financial Aid (Title IV) as well as calculating return of Title IV funds for students...

Condition: Due to the limited number of personnel within the Financial Aid Department, the director of financial aid is solely responsible for packaging, awarding, and disbursing to student accounts Federal Student Financial Aid (Title IV) as well as calculating return of Title IV funds for students who withdraw from the School to student accounts. The packaging of Title IV aid and the return of Title IV funds are complex calculations that are not formally reviewed by another employee. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. This third-party processing company is structured to properly segregate financial processing and includes a quality review function. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

View Audit 346899

Finding 522899 (2023-002)

Significant Deficiency 2023

Clarkson University

NY

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

Management accepts this finding and notes that loan disbursement notifications are automatically sent to students (we mail notifications to parents and have copies of those saved). There was a glitch in the system that was discovered while going through the audit that occurred on 2 dates in 2023 (Ma...

Management accepts this finding and notes that loan disbursement notifications are automatically sent to students (we mail notifications to parents and have copies of those saved). There was a glitch in the system that was discovered while going through the audit that occurred on 2 dates in 2023 (May 31, 2023 and September 3, 2023) which has since been fixed. Financial Aid worked with the Office of Information Technology to develop a daily report that will notify the Director of Financial Aid of anyone that did not receive a notification.

View Audit 342222

Finding 522452 (2023-011)

Material Weakness 2023

Arkansas Baptist College

AR

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

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to disbursing loans within aggregate loan limits. Responsible Administrators: Director of Financial Aid Effective: Immediately and ongoing

View Audit 341725

Finding 522445 (2023-010)

Material Weakness 2023

Arkansas Baptist College

AR

Student Financial Aid Subrecipient Monitoring Reporting § 200.512

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to competing and submitting the audit. The College has a new CFO and Controller. These measures will ensure stability and a timely audit. Responsible Administ...

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to competing and submitting the audit. The College has a new CFO and Controller. These measures will ensure stability and a timely audit. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective immediately and ongoing

View Audit 341725

Corrective Action Plans

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