Corrective Action Plans

Finding 546915 (2024-005)

Material Weakness 2024

IL

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

Finding No. 2024-005 Failure to Notify Recipients of Federal Direct Loan and Federal Pell Grant Disbursements ALNs: 84.063, 84.268 Program: Student Financial Assistance Cluster Corrective Action: The University created an automated process to send financial aid notifications on a regular basis. Comp...

Finding No. 2024-005 Failure to Notify Recipients of Federal Direct Loan and Federal Pell Grant Disbursements ALNs: 84.063, 84.268 Program: Student Financial Assistance Cluster Corrective Action: The University created an automated process to send financial aid notifications on a regular basis. Completed: January 31, 2024 Contact Person: Amanda Fijal

View Audit 351271

Finding 546912 (2024-004)

Material Weakness 2024

The University of Chicago

IL

Questioned Costs Student Financial Aid Allowable Costs / Cost Principles § 200.303

Finding No. 2024-004 Failure to Properly Complete Required Verification Procedures ALNs: 84.007, 84.033, 84.063, 84.268 Program: Student Financial Assistance Cluster Corrective Action: Additional training will be provided to staff. Implementation Date: June 30, 2025 Contact Person: Amanda Fijal

View Audit 351271 Questioned Costs: $1

Finding 546911 (2024-003)

Material Weakness 2024

The University of Chicago

IL

Questioned Costs Matching / Level of Effort / Earmarking Student Financial Aid § 200.303

Finding No. 2024-003 Failure to Determine Eligibility in Accordance with SFA Regulations ALNs: 84.007, 84.033, 84.063, 84.268 Program: Student Financial Assistance Cluster Corrective Action: Additional training will be provided to staff. Implementation Date: June 30, 2025 Contact Person: Amanda Fija...

Finding No. 2024-003 Failure to Determine Eligibility in Accordance with SFA Regulations ALNs: 84.007, 84.033, 84.063, 84.268 Program: Student Financial Assistance Cluster Corrective Action: Additional training will be provided to staff. Implementation Date: June 30, 2025 Contact Person: Amanda Fijal

View Audit 351271 Questioned Costs: $1

Finding 544783 (2024-005)

Significant Deficiency 2024

Chestnut Hill College

PA

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

2024-005 Federal Supplemental Educational Opportunity Grants; Federal Pell Grant Program; Federal Direct Student Loans; Teacher Education Assistance for College and Higher Education Grants - Assistance Listing No. 84.007, 84.063, 84.268, 84.379 Recommendation: The College should develop and implemen...

2024-005 Federal Supplemental Educational Opportunity Grants; Federal Pell Grant Program; Federal Direct Student Loans; Teacher Education Assistance for College and Higher Education Grants - Assistance Listing No. 84.007, 84.063, 84.268, 84.379 Recommendation: The College should develop and implement an approved written information security program and verify there is a risk management section that describes how the College is identifying, assessing and communicating risks. In addition, there should be a description on the evaluation of safeguard sufficiency in mitigating risks. The information security program should also include the following: • IT Security Policy • Acceptable Use Policy • Incident Response Policy • Data Classification Policies • Vendor Management Policy • Patch Management Policy • Data Disposal Policy • Risk Assessment Policy • Logical Access and User Access Review Policies • Evidence of Review by CIO/CISO and responsibility of program Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will develop and implement an information security program to verify our risk management efforts. This plan will identify how we are identifying, assessing and communicating risk. Name(s) of the contact person(s) responsible for corrective action: Scott Seidman, Director of IT Planned completion date for corrective action plan: June 30, 2025

View Audit 351264

Finding 544781 (2024-004)

Significant Deficiency 2024

Chestnut Hill College

PA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

2024-004 Federal Pell Grant Program; Federal Direct Student Loans -Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the C...

2024-004 Federal Pell Grant Program; Federal Direct Student Loans -Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the College review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of the Registrar is reviewing its policies and procedures to ensure that all data is captured and reported in a timely manner as required by federal regulations. A software issue that caused inaccurate data to be reported has been identified and resolved by a software update. The Office of the Registrar is working with the Office of Information Technology to test the accuracy of the updated software. Name(s) of the contact person(s) responsible for corrective action: Micheal Reig, Registrar Planned completion date for corrective action plan: June 30, 2025

View Audit 351264

Finding 544777 (2024-003)

Significant Deficiency 2024

Chestnut Hill College

PA

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

2024-003 Federal Supplemental Educational Opportunity Grants; Federal Pell Grant Program; Federal Direct Student Loans; Teacher Education Assistance for College and Higher Education Grants- Assistance Listing Nos: 84.007, 84.063, 84.268, 84.379 Recommendation: We recommend the College review the R2T...

2024-003 Federal Supplemental Educational Opportunity Grants; Federal Pell Grant Program; Federal Direct Student Loans; Teacher Education Assistance for College and Higher Education Grants- Assistance Listing Nos: 84.007, 84.063, 84.268, 84.379 Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into the R2T4 calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Financial Aid will work with the Registrar to ensure that we receive the academic calendar in a timely manner. Once received, breaks will be verified by the Assistant Director of Financial Aid and then confirmed by the Director of Financial Aid. Name(s) of the contact person(s) responsible for corrective action: Jossie Johnson, Director of Financial Aid Planned completion date for corrective action plan: June 30, 2025

View Audit 351264 Questioned Costs: $1

Finding 544776 (2024-002)

Significant Deficiency 2024

Chestnut Hill College

PA

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

2024-002 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding:...

2024-002 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: While the Office of Financial Aid has revamped how it manages exit notices and has made an improvement, our report has failed to pick up students that went from undergraduate to graduate in consecutive semesters. We will develop and implement a new report to ensure that this population is picked and exit notices are sent in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Jossie Johnson, Director of Financial Aid, and Micheal Reig, Registrar Planned completion date for corrective action plan: June 30, 2025

View Audit 351264

Finding 544706 (2024-002)

Significant Deficiency 2024

Tabor College, Inc.

KS

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Criteria or Specific Requirement - The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the chang...

Criteria or Specific Requirement - The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition - We noted discrepancies in the data reported in NSLDS compared to the data in the College’s records. Cause - The College’s processes and controls did not ensure that the effective dates were properly reported to NSLDS. Effect or potential effect - The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Questioned costs - None Context - During our testing, we noted for three out of eleven students tested, the program begin date per the institution did not match the student's effective date reported to NSLDS. In addition, we noted for one out of eleven students tested the notification was not made within 60 days. Sampling was not a statistically valid sample. Identification as a repeat finding, if applicable - 2023-003 Recommendation - We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials and planned corrective actions - Management concurs with the findings and recommendations. See separate report for planned corrective actions. Views of Responsible Officials and Corrective Action Plan – Management concurs with the findings and recommendation. Responsible personnel will review current guidance available from the Department of Education website and develop internal procedures to ensure timely compliance. This plan will include personnel and responsibility redundancy to account for employee absences or turnover, and a continuous review of available guidance to ensure the College stays current with any changes to this guidance. Additionally, monthly reconciliations have been added to the College’s procedures to ensure any errors are caught in a timely manner. Individual Responsible – Caleb Loss, Vice President for Business and Finance Anticipated Completion Date – April 2025

View Audit 351214

Finding 544690 (2024-004)

Significant Deficiency 2024

Tusculum University

TN

Subrecipient Monitoring Student Financial Aid Significant Deficiency

2024-004 Significant Deficiency: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) (Repeat Finding: 2023-002) Name of Contact Person Casey Reagan, Registrar, and Chris Summey, Head of our IT Department, are the designated employees in cha...

2024-004 Significant Deficiency: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) (Repeat Finding: 2023-002) Name of Contact Person Casey Reagan, Registrar, and Chris Summey, Head of our IT Department, are the designated employees in charge of overseeing the GLBA Policy Corrective Action Planned During the audit, it was noted that the University’s Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University during the 2024 year. A new policy was put into place during June 2024. During the 2023-24 academic year, the policy was being updated to be compliant. Due to this finding in 2022-23, the FSA Cyber Compliance Team reached out to Tusculum and Tusculum provided the Corrective Action Plan and new policy. On August 1st, 2024, Tusculum received word that the CAP acceptably addressed the GLBA finding. Anticipated Completion Date 08/1/2024

View Audit 351195

Finding 544689 (2024-005)

Significant Deficiency 2024

Tusculum University

TN

Student Financial Aid Reporting Significant Deficiency

2024-005 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001 and 2023-003) Name of Contact Person Casey Reagan, Registrar, an...

2024-005 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001 and 2023-003) Name of Contact Person Casey Reagan, Registrar, and Melissa White, Director of Financial Aid, are responsible for enrollment reporting. Casey Regan for the data and Melissa White for uploading the report to clearinghouse. Corrective Action Planned During the audit, it was noted that Due to lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. While the university did implement changes from the prior year, including randomly sampling students, after this finding and looking into the issue that was occurring, we found three more issues with our clearinghouse data. The first issue was our graduation file that was sent to clearinghouse was not being processed and being rejected. We were unaware of the rejection of the records. We have worked with a clearinghouse representative and created a new way of pulling the graduate students report to ensure that their status is properly reported and sent to NSLDS. The second issue was that some student files were individually being rejected and thus not processing fully through. To correct this issue, we are watching the rejected clearinghouse files for individual students and are manually reporting their statuses if we cannot get the file to accept. The final and third issue was that students who were unofficially or administratively withdrawn were pulling the wrong date and thus the status was showing the wrong dates for the occurrence. To fix this, financial aid and the registrar are working in tandem to ensure that the correct date that the actual unofficial withdrawal or administrative withdrawal is correct. If necessary, we will manually certify these students as well. Anticipated Completion Date 03/01/2025

View Audit 351195

Finding 544688 (2024-003)

Significant Deficiency 2024

Tusculum University

TN

Student Financial Aid Reporting Significant Deficiency

2024-003 Significant Deficiency: Federal Work-Study (FWS) (U.S. Department of Education, Federal Work-Study Program, ALN #84.033) Name of Contact Person Melissa White, Director of Financial Aid, is responsible for ensuring that Federal Work Study students are not working during class time. Correct...

2024-003 Significant Deficiency: Federal Work-Study (FWS) (U.S. Department of Education, Federal Work-Study Program, ALN #84.033) Name of Contact Person Melissa White, Director of Financial Aid, is responsible for ensuring that Federal Work Study students are not working during class time. Corrective Action Planned During the audit, it was noted that Tusculum failed to compare hours submitted as worked hours to student class schedules. In order to ensure that this does not occur again, all supervisors have been reminded of the requirement that students do not work during seat time. Regular reminders sent to supervisors and regular trainings are offered to supervisors to remind supervisors of the Federal Work Study Guidelines. In addition, as each timesheet is submitted, financial aid shall check to ensure no violations have occurred. Anticipated Completion Date 10/15/2024

View Audit 351195

Finding 544687 (2024-002)

Significant Deficiency 2024

Tusculum University

TN

Student Financial Aid Reporting Significant Deficiency

2024-002 Significant Deficiency: Federal Work-Study (FWS) Underpayment (U.S. Department of Education, Federal Work-Study Program, ALN #84.033) Name of Contact Person Melissa White, Director of Financial Aid, is responsible for ensuring that Federal Work Study students are properly paid for hours w...

2024-002 Significant Deficiency: Federal Work-Study (FWS) Underpayment (U.S. Department of Education, Federal Work-Study Program, ALN #84.033) Name of Contact Person Melissa White, Director of Financial Aid, is responsible for ensuring that Federal Work Study students are properly paid for hours worked. Corrective Action Planned During the audit, it was noted that Tusculum errantly miscalculated hours worked and wages payable results in student receiving fewer Title IV funds than what they may have earned or be eligible for. Once found, the missing hours were added to the next payroll and the students were paid. To ensure this error does not occur again in the future, financial aid has created a secondary check system that includes keeping an additional excel that confirms that each timesheet has been paid for each student and that their full hours worked have been paid. We have also reinforced with supervisors the urgency of making sure timesheets are submitted in a timely manner so that the error does not occur again as the timesheets in question were late timesheets. Additional training for supervisors and constant reminders to supervisors are also ongoing. Anticipated Completion Date 10/15/2024

View Audit 351195

Finding 544631 (2024-001)

Significant Deficiency 2024

Trustees of the College of the Holy Cross

MA

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

Corrective Action Plan: The identified conditions relate to students who graduated off-cycle. To mitigate the risk of future status change reporting issues, the College is implementing an additional monthly review process that will generate a report of students who have separated from the College. T...

Corrective Action Plan: The identified conditions relate to students who graduated off-cycle. To mitigate the risk of future status change reporting issues, the College is implementing an additional monthly review process that will generate a report of students who have separated from the College. This report will be reconciled with student status changes transmitted by the National Student Clearinghouse (NSC) to the National Student Loan Database System (NSLDS), and any necessary corrections will be made immediately. Timeline for Implementation of Corrective Action Plan: These corrective actions are being implemented in Spring 2025.

View Audit 351172

Finding 544518 (2024-003)

Significant Deficiency 2024

Allen University

NC

Questioned Costs Student Financial Aid Procurement, Suspension & Debarment

Finding 2024-003 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiencies): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. 1) The College...

Finding 2024-003 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiencies): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. 1) The College did not reconcile the following programs between the Office of Financial Aid and the Business Office. Per 34 CFR 685.300(b)(5). a. Federal Pell Grant Program b. Federal Direct Student Loans c. Federal SEOG d. Federal Work-Study (FWS) Program 2) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations Report and Application to Participate (FISAP) for the programs below: a. Federal Pell Grant Program b. Federal Work-Study (FWS) Program c. Federal SEOG 3) Thirty-two out of 60 students had a credit balance on their account created by Title IV program funds longer than 14 days. 34 CFR 668.164(h)(1). Auditor's Recommendation – The University should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. Corrective Action – Refunds – The refund non-compliance is contributed to the institution’s ERP (Jenzabar) not being operational for about 7 months. This hindered the staff’s ability to properly review and process student refunds timely. The institution has a process in place to ensure compliance of distribution and is also enhancing the student refund module to improve timeliness of refund distribution. Federal Reconciliations and FISAP – The non-compliance is contributed to the institution’s ERP (Jenzabar) not being operational for about 7 months. This hindered the staff’s ability to properly reconcile federal funds timely and assurance in accuracy in completing the FISAP. In addition, the software enhancements for the Accounting modules, the institution has purchased a system enhancement for Financial Aid to be able to centralize FA processing and generate Federal Reconciliations and FISAP report. The Jenzabar Financial Aid software will assist the institution with maintaining compliance with all external federal reporting.

View Audit 351159 Questioned Costs: $1

Finding 544471 (2024-001)

Significant Deficiency 2024

American International College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action Plan: In March of 2024, the College created a policy that implemented scheduled disbursement dates to ensure the timely recording of disbursement dates. The finding for June 30, 2024, single audit occurred before the new policy was in effect. The number of findings also decreased...

Corrective Action Plan: In March of 2024, the College created a policy that implemented scheduled disbursement dates to ensure the timely recording of disbursement dates. The finding for June 30, 2024, single audit occurred before the new policy was in effect. The number of findings also decreased, and students audited after the corrective action was put into place were done correctly. To continue to mitigate this from occurring in the future, the College has implemented a report that will show differences in the date Direct Student Loan funds are disbursed in Powerfaids versus the date the funds are applied to a student’s ledger, and date shown as disbursed in COD. All differences will be investigated and rectified on a biweekly basis. Timeline for Implementation of Corrective Action Plan: Implemented in March 2024 Contact Person Lynn Comtois Director of Financial Aid

View Audit 351150

Finding 544397 (2024-001)

Significant Deficiency 2024

Michigan State University

MI

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility

Condition: The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Planned Corrective Action: Missing notifications to students was a result of a coding error in the automated process that was resolved on S...

Condition: The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Planned Corrective Action: Missing notifications to students was a result of a coding error in the automated process that was resolved on September 5, 2023. Notifications to parents didn’t begin until the Summer 2023, with an automated procedure being implemented in the Fall 2023 semester. A coding issue was identified and resolved in the automated procedure to notify parents in early January 2024. Contact person responsible for corrective action: Kent McGowan, Assistant Director, Office of Financial Aid Anticipated Completion Date: This finding was corrected as of January 2024.

View Audit 351055

Finding 544337 (2024-001)

Material Weakness 2024

Dominican University

IL

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring

Reporting – The University will review and update current procedures to ensure timely processing and monitoring of NSLDS reports. Internal reports will be run simultaneously to make sure all students are captured and their status is correctly reported. Anticipated Completion Date - September 30, ...

Reporting – The University will review and update current procedures to ensure timely processing and monitoring of NSLDS reports. Internal reports will be run simultaneously to make sure all students are captured and their status is correctly reported. Anticipated Completion Date - September 30, 2024; Responsible Contact Person for Planned Corrective Action - Tina Baskin, Executive Director of Financial Aid & Enrollment Services

View Audit 350931

Finding 544176 (2024-005)

Significant Deficiency 2024

Delaware State University

DE

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

2024-005 Student Financial Assistance Cluster – CFDA Nos. 84.063, 84.033 and 84.268 – Credit Balances Recommendation: We recommend that the University reevaluate its process to ensure that credit balances on student accounts due to the application of title IV funds are refunded within 14 days. Expla...

2024-005 Student Financial Assistance Cluster – CFDA Nos. 84.063, 84.033 and 84.268 – Credit Balances Recommendation: We recommend that the University reevaluate its process to ensure that credit balances on student accounts due to the application of title IV funds are refunded within 14 days. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: ERP (Banner) system was being used to generate reporting for credit balances. A glitch was discovered using this process due to application of payment. Student Accounts change the reporting method to Argos, which provided a more accurate and timely report of all credit balances regardless of the disbursement term. Name(s) of the contact person(s) responsible for corrective action: AVP of Student Accounts, Carold Boyer-Yancy & Senior Associate Director of Operations, Lindsay Sands Planned completion date for corrective action plan: December 2024

View Audit 350927

Finding 544175 (2024-004)

Significant Deficiency 2024

Delaware State University

DE

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

2024-004 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, and 84.268 – Outstanding Refund Checks Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior...

2024-004 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, and 84.268 – Outstanding Refund Checks Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior to the 240-day deadline. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: The Assistant Controller will implement review procedures for timely reconciliation of bank and ledger accounts & maintain an accurate listing of those discrepancies. This information will be timely shared with respective teams to address. Name(s) of the contact person(s) responsible for corrective action: Assistant Controller, Clifton Smith, II. Planned completion date for corrective action plan: July 2025

View Audit 350927

Finding 544174 (2024-003)

Material Weakness 2024

Delaware State University

DE

Matching / Level of Effort / Earmarking Student Financial Aid Material Weakness § 200.303

2024-003 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally...

2024-003 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar’s Office will review and strengthen the enrollment report to ensure it pulls all required information according to the needs of the National Student Clearinghouse (NSCL) and the National Student Loan Data System (NSLDS). The Registrar’s Office will continue to work with the National Student Clearinghouse (NSCL) and National Student Loan Data System (NSLDS) on the specific enrollment submission scenarios that require a different submission/update requirement. Name(s) of the contact person(s) responsible for corrective action: University Registrar, Dr. Genita Mangum Planned completion date for corrective action plan: December 2025

View Audit 350927

Finding 544159 (2024-007)

Significant Deficiency 2024

Washington Adventist University

MD

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

Action taken in response to finding: A formal review of will take place of NSLDS reporting. Written policy with a monthly checklist will be developed to be in compliance with the regulation for student statuses. Name(s) of the contact person(s) responsible for corrective action: Patrick Farley Plan...

Action taken in response to finding: A formal review of will take place of NSLDS reporting. Written policy with a monthly checklist will be developed to be in compliance with the regulation for student statuses. Name(s) of the contact person(s) responsible for corrective action: Patrick Farley Planned completion date for corrective action plan: June 30, 2025

View Audit 350924

Finding 544141 (2024-006)

Significant Deficiency 2024

Washington Adventist University

MD

Subrecipient Monitoring Student Financial Aid

Action taken in response to finding: To address the identified deficiencies in WAU’s written information security program and ensure compliance with 16 CFR § 314.4, the following actions have been taken: 1. Approval of the Information Security Program: o Action: We have updated the written informat...

Action taken in response to finding: To address the identified deficiencies in WAU’s written information security program and ensure compliance with 16 CFR § 314.4, the following actions have been taken: 1. Approval of the Information Security Program: o Action: We have updated the written information security program as formally approved by the appropriate individual within the institution, Rosalee Pedapudi, ITS Director. This step designates a qualified individual responsible for overseeing and implementing the information security program as a requirement under 16 CFR § 314.4(a). 2. Design and Implementation of Safeguards: o Action: According to 16 CFR § 314.4(c), institutions must implement safeguards to control identified risks, including encryption of customer information in transit and at rest. We have documented specific safeguards to control the risks identified through the institution's risk assessment, including a policy mandating the encryption of customer information both on the institution's systems and during transmission. As such, the university encrypts Non-Public Financial information both at rest and in transit using industry-standard encryption protocols (e.g. VPN). Where encryption is not feasible, compensating controls are implemented to protect sensitive data. The university also requires Multifactor Authentication (MFA) for systems that process, store, or transmit protected financial information. Access is governed by the principle of least privilege, with privileged access granted by authorized university officers, ensuring that only approved personnel can access sensitive data. 3. Regular Testing and Monitoring of Safeguards: o Action: According to 16 CFR § 314.4(d), WAU is required to regularly test and monitor the effectiveness of their safeguards to ensure the security of customer information. We have established procedures for annual penetration testing through Applied Technology Services and monitoring of the effectiveness of the implemented safeguards. Name(s) of the contact person(s) responsible for corrective action: Rosalee Pedapudi Planned completion date for corrective action plan: July 15, 2025.

View Audit 350924

Finding 544139 (2024-003)

Significant Deficiency 2024

Washington Adventist University

MD

Questioned Costs Eligibility Student Financial Aid § 200.303

Action taken in response to finding: The University has SAP policies and procedures in place to determine student’s eligibility for Financial Aid that complies with Federal regulations, including qualitative (GPA), quantitative (pace of completion) and maximum timeframe standards. The SAP finding m...

Action taken in response to finding: The University has SAP policies and procedures in place to determine student’s eligibility for Financial Aid that complies with Federal regulations, including qualitative (GPA), quantitative (pace of completion) and maximum timeframe standards. The SAP finding may be due to system error with the Colleague ERP when the SAP report was run. The University will evaluate our SAP procedures and perform internal audits to identify gaps or inconsistencies and implement corrective actions as needed. Training will be provided to financial aid staff on SAP requirements and procedures to ensure consistent application and understanding. Name(s) of the contact person(s) responsible for corrective action: Alfred Taylor Planned completion date for corrective action plan: June 30, 2025

View Audit 350924 Questioned Costs: $1

Finding 544138 (2024-002)

Material Weakness 2024

Washington Adventist University

MD

Student Financial Aid Internal Control / Segregation of Duties Cash Management § 200.303

Action taken in response to finding: Washington Adventist University (WAU) is evaluating its current internal control and will make the necessary improvements so as to assure accuracy and compliance with the laws and regulations applicable to WAU. Furthermore, WAU will map internal control to impro...

Action taken in response to finding: Washington Adventist University (WAU) is evaluating its current internal control and will make the necessary improvements so as to assure accuracy and compliance with the laws and regulations applicable to WAU. Furthermore, WAU will map internal control to improve segregation of duties where possible and follow the Committee of Sponsoring Organizations of the Treadway Commission best practices for small business. Name(s) of the contact person(s) responsible for corrective action: Alfred Taylor Planned completion date for corrective action plan: June 30, 2025.

View Audit 350924

Finding 544136 (2024-001)

None 2024

Trinity Christian College

IL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

All graduate and withdrawn student files will be reviewed on a monthly basis to verify any status changes are reported to NSLDS within regulatory timeframes. Training and professional development will be required for responsible staff to ensure a compliance schedule is developed. Personnel will be e...

All graduate and withdrawn student files will be reviewed on a monthly basis to verify any status changes are reported to NSLDS within regulatory timeframes. Training and professional development will be required for responsible staff to ensure a compliance schedule is developed. Personnel will be evaluated to ensure existing policies, procedures, and processes are followed and supported through corrective action where needed.

View Audit 350923

Corrective Action Plans

Filters