Corrective Action Plans

Finding 513951 (2024-002)

Significant Deficiency 2024

KS

Special Tests & Provisions Student Financial Aid Reporting

SIGNIFICANT DEFICIENCY 2024-002 Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Enrollment Reporting Condition During testing, we identified that 6 of the 60 students tested did not have an enrollment status change properly reported. Re...

SIGNIFICANT DEFICIENCY 2024-002 Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Enrollment Reporting Condition During testing, we identified that 6 of the 60 students tested did not have an enrollment status change properly reported. Recommendation We recommend that the College review its controls to ensure that accurate enrollment information is reported to NSLDS. Comments on the Finding Recommendation Barton County Community College understands the finding. Action Taken Barton County Community College has updated its policies and procedures to reflect emphasis on reporting the unofficial withdrawals to NSLDS within 30 days. Barton’s Financial Aid Office will perform a quality assurance review of NSLDS to ensure that the unofficial withdrawals have been reported. Additionally, Barton’s Registrar will perform a periodic check to see if other enrollment reporting is reflected accurately in the National Student Clearinghouse and the National Student Loan Data System. Date of implementation: This has been implemented for the 2024-2025 award year.

View Audit 332157

Finding 513948 (2024-001)

Material Weakness 2024

Barton County Community College

KS

Student Financial Aid Material Weakness Reporting

MATERIAL WEAKNESS 2024-001 Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Return to Title IV and Enrollment Reporting Condition The College's official policy is to be an attendance taking institution. However, the date of the institution’...

MATERIAL WEAKNESS 2024-001 Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Return to Title IV and Enrollment Reporting Condition The College's official policy is to be an attendance taking institution. However, the date of the institution’s determinations for withdrawals does not fall within the required 14 day period, and it instead follows that of institutions that are not attendance taking. Additionally, during testing, it was identified that the College's quality control processes for Return to Title IV calculations were not completed within a timely manner, and that process determined that calculations needed to be adjusted for some of the students. Those corrections were not made within the required 45 day periods, and, as a result of the late corrections, the NSLDS enrollment reporting also had to be updated outside of its typical window. Recommendation We recommend that the College review and update its policies to ensure that all compliance requirements are met within the required timeframes associated with those policies, as well as recommend that the College review its controls to ensure that accurate Return to Title IV calculations are completed in a timely fashion. Comments on the Finding Recommendation Barton County Community College understands the finding. Action Taken Barton’s Director of Financial Aid has informed the following Barton personnel of the finding: • Vice President of Instruction, • Vice President of Student Services, • Dean of Academics, the Dean of Workforce Training and Community Education • Dean of Military Programs, Technical Education, and Outreach Programs • Associate Dean of Instruction The Vice President of Instruction is initiating a project to involve these parties in the implementation of a procedure to report unofficial withdrawals by 14 calendar days to ensure Return of Title IV is completed within the regulatory timeframes and reported to NSLDS within the regulatory timeframe. Date of Implementation: This will be implemented for the spring 2025 term.

View Audit 332157

Finding 513933 (2024-001)

Significant Deficiency 2024

Fort Hays Tech North Central

KS

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Condition: Not all Graduate status changes were updated in the NSLDS system. Criteria: The College is responsible for reporting student status changes to the NSLDS. Cause: Miscommunication between the Clearinghouse and College on which file is used to update the degree status. Effect: Loan...

Condition: Not all Graduate status changes were updated in the NSLDS system. Criteria: The College is responsible for reporting student status changes to the NSLDS. Cause: Miscommunication between the Clearinghouse and College on which file is used to update the degree status. Effect: Loan repayment status was not started on time. Perspective: College reports using the National Student Clearinghouse. The College believed the Clearinghouse was using the Degree Verify file to update the status, but the Clearinghouse was using the Enrollment File in mid-May. Recommendation: We agree with the College’s plan of action below.ures and catching up submissions.

View Audit 332144

Finding 513930 (2024-001)

Significant Deficiency 2024

New England Law / Boston

MA

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

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2024 Award Year; U.S. Department of Education Criteria or Specific Requirement ...

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2024 Award Year; U.S. Department of Education Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves-of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022 and 34 CFR 682.610) Condition Found Of the 15 students selected for enrollment reporting testing, one student within the sample was reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Upon further inquiry, there were an additional 7 students included in the same batch reported to NSLDS that were not reported timely. Views of Responsible Officials and Planned Corrective Actions The School concurs with the finding. The School intends to report student status changes at year end. Names of Contact Person Responsible for Corrective Action: Andy Vidal, Chief Financial Officer, and Daniel Miller, Director on Financial Aid Anticipated Completion Date: December 31, 2024 Summary Schedule of Prior Audit Findings None

View Audit 332140

Finding 513910 (2024-003)

Significant Deficiency 2024

Heartland Community College District #540

IL

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

Finding A: Verification V1 Corrections. The college during a verification review process did not send a tax paid correction to FSA. The correction was made in the system, but was not flipped to (send) out to FSA. The financial aid office will at new procedure that will pull all pending corrections t...

Finding A: Verification V1 Corrections. The college during a verification review process did not send a tax paid correction to FSA. The correction was made in the system, but was not flipped to (send) out to FSA. The financial aid office will at new procedure that will pull all pending corrections to double check to ensure any corrections made in the Financial Aid System will be sent. This process will rely on a weekly query to identify any correction made to an ISIR and provide a report for financial aid officer to review and confirm correction was completed thru FSA. Finding B: Verification V4 & V5 missing date. The financial aid process requires all students selected for V4 and V5 verification to complete Identity verification form in person. Staff are required to sign and date the documents in front of the students upon confirmation of identity. The office staff signed the forms, but did not date document. All documents had student signature and date student signed in front of staff, staff signature was completed as well, but in these cases the date verification occurred was not noted. The financial aid office completed a self-audit on 101 files selected for verification to confirm all signatures and dates were completed. Based upon additional review the financial aid team did not find any other documents that were missing signatures or dates. The financial aid office will review verification trainings on FSA and develop a business process that requires a second reviewer to confirm the documents are complete prior to closure of the file. Finding C: NSLDS last date of reporting. The financial aid office completed an internal audit reviewing all student withdraws to ensure reporting was accurate with clearinghouse and NSLDS. If last date of attendance did not match institutional records, the financial aid office updated correct values on NSLDS and Clearinghouse. No errors were found pertaining to fall 2023 enrollment. The errors found pertaining to the spring 2024 term including noted findings were updated and records office was notified to ensure data reported on rosters reflecting last date of attendance is reflected in the student enrollment tables. The financial aid office is working with institutional research to develop a process that will check to tables to ensure data is correct prior to submittal to clearinghouse and/or NSLDS. The process will query data from enrollment, midterm grade rosters and Clearinghouse report to make sure data matches. Incorrect data will be updated prior to submittal to clearinghouse and NSLDS. Person(s) Responsible: Director of Financial Aid Timing for Implementation: New procedures have already been implemented.

View Audit 332131

Finding 513901 (2024-001)

None 2024

Union University

TN

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

Return of Title IV Funds for Failure to Begin Attendance Planned Corrective Action: Management agrees with the auditors' comments, and the following actions will be taken to ensure compliance with Return of Title IV Funds for Failure to Begin Attendance. • The University’s Title IV Aid Committee con...

Return of Title IV Funds for Failure to Begin Attendance Planned Corrective Action: Management agrees with the auditors' comments, and the following actions will be taken to ensure compliance with Return of Title IV Funds for Failure to Begin Attendance. • The University’s Title IV Aid Committee convened on November 18, 2024, to address strategies for ensuring that appropriate documentation related to the unofficial withdrawal process is accurately collected by the Student Financial Aid Office. • To enhance the process, in addition to contacting professors via email for all students receiving zero credits in a term, two additional fields will be incorporated into the university's grading system. These fields will enable professors to indicate whether a student never attended the course and to record the last date of attendance. Amount Returned to the United States Department of Education: $5,071 • $5,071 was returned for the questioned student identified during the audit on November 20, 2024. It was determined that the student never started the course, and the entire amount of the loan was returned. Person Responsible for Corrective Action Plan: Colby Benefield, Director of Student Financial Aid Anticipated Date of Completion: January 01, 2025

View Audit 332071 Questioned Costs: $1

Finding 513861 (2024-003)

Significant Deficiency 2024

Arlington Baptist University

CO

Student Financial Aid Allowable Costs / Cost Principles Significant Deficiency

Lack of Documentation of Exit Counseling Planned Corrective Action: Current SIS is set to trigger the Exit Counseling to all students that are coded anything other than E (Enrolled). The Registrar updates all student files with any enrollment changes triggering the email to go to the student. The FA...

Lack of Documentation of Exit Counseling Planned Corrective Action: Current SIS is set to trigger the Exit Counseling to all students that are coded anything other than E (Enrolled). The Registrar updates all student files with any enrollment changes triggering the email to go to the student. The FA Director will run a report in the middle of each term to pick up any students that may have been missed by the Registrar. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2024

View Audit 331877

Finding 513859 (2024-002)

Significant Deficiency 2024

Arlington Baptist University

CO

Questioned Costs Student Financial Aid Significant Deficiency

Return of Title IV (R2T4) Calculations Planned Corrective Action: Calander was set using prior year information it was not until notification in April 2024 from the DOE Audit Resolution Group that the error was made known to Financial Aid Director. Prior year R2T4 was handled by 3rd party vendor. T...

Return of Title IV (R2T4) Calculations Planned Corrective Action: Calander was set using prior year information it was not until notification in April 2024 from the DOE Audit Resolution Group that the error was made known to Financial Aid Director. Prior year R2T4 was handled by 3rd party vendor. The calendar for 2023-2024 was updated immediately and all calculations were processed and adjustments made. The ABU director has now taken NASFAA R2T4 Specialist training and is in charge of updating and maintaining the calendar. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2024

View Audit 331877 Questioned Costs: $1

Finding 513858 (2024-001)

Material Weakness 2024

Arlington Baptist University

CO

Reporting Student Financial Aid Eligibility

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: ABU started working on partnering with the National Clearing House in the fall 2023 for NSLDS reporting. Due to a system conversion at the time this process took longer than anticipated. However,...

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: ABU started working on partnering with the National Clearing House in the fall 2023 for NSLDS reporting. Due to a system conversion at the time this process took longer than anticipated. However, the first error free report was uploaded 09/01/2024. ABU now has a schedule with set reminders from the clearinghouse to ensure timely and regular reporting. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2024

View Audit 331877

Finding 513853 (2024-001)

Significant Deficiency 2024

Carroll Community College

MD

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

U.S. Department of Education 2024-001 Special Tests and Provisions – NSLDS Program-Level Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: The associate degree programs were not reported as two years per the recommendation in the NSLDS enrollment reporting...

U.S. Department of Education 2024-001 Special Tests and Provisions – NSLDS Program-Level Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: The associate degree programs were not reported as two years per the recommendation in the NSLDS enrollment reporting guide. Recommendation: We recommend the College report associate degree program length to NSLDS as two years. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: After being made aware of the NSLDS calculation for programs reported that aren’t reported in years, we looked into solving the issue. We learned that there is a screen within our student information system that sets the default time to years rather than months. Our degree programs prior to 2017 were entered into that screen but degree programs after that time and all of our certificate programs, needed to be calculated as years and entered into our SIS. We did a small trial sample of adjusting three programs in the spring to make sure the changes did not cause any issues with the Clearinghouse and NSLDS. When the data proved to be transmitted and corrected in both systems without issue, we tackled the rest of the programs at the start of this fall. We worked with the Clearinghouse to notify them that we were going to be adjusting a large number of programs that were effecting many student records. They did some alignment of our programs on their end to make the data transition go smoothly to the NSLDS. Issues with reported program lengths having the additional calculation should no longer. We have built in processes to make sure this step will be taken for any new programs. Name(s) of the contact person(s) responsible for corrective action: Greg Bricca, Director of Institutional Effectiveness

View Audit 331869

Finding 513831 (2024-001)

Significant Deficiency 2024

Doane University

NE

Student Financial Aid Subrecipient Monitoring Significant Deficiency

To address this finding, we will implement a documented system of controls for all Title IV refund calculations. This will include: Each R2T4 calculation will undergo a documented review by a secondary individual. This review will be recorded via either a signature and date on the worksheet or an em...

To address this finding, we will implement a documented system of controls for all Title IV refund calculations. This will include: Each R2T4 calculation will undergo a documented review by a secondary individual. This review will be recorded via either a signature and date on the worksheet or an email confirmation. Name(s) of Contact Person(s) Responsible for Corrective Action: Federico Peña Jr. (Fred), Financial Aid Director Anticipated Completion Date: November 6, 2024

View Audit 331806

Finding 513760 (2024-001)

Significant Deficiency 2024

St. Catherine University

MN

Student Financial Aid Reporting Significant Deficiency

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

Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar's Office partnered with IT to automate the transmission of enrollment and graduation files to the National Student Clearinghouse to avoid late submissions or confusion about which branch the transmission is reporting. They have been set up to be sent on the same day each month, rather than being sent manually by a staff member. Several staff members met with our NSC representative to review the transmission schedule to ensure the selected dates will lead to timely submissions. Name of the contact person responsible for corrective action: Kerri Vickers, Registrar Planned completion date for corrective action plan: December 2024

View Audit 331691

Finding 513758 (2024-001)

Material Weakness 2024

Clarke University of Dubuque, Iowa

IA

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

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans ‐ 2023/2024 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program ‐ 2023/2024 P063P201430 Special Tests & Provisio...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans ‐ 2023/2024 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program ‐ 2023/2024 P063P201430 Special Tests & Provisions:– Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary: One instance was identified where there was no documented return of Title IV calculation, and fourteen instances were identified where there was no documented review of the return of Title IV calculation. Responsible Individuals: Robert Hoover, Director of Financial Aid and Sylma Fernandez, Assistant Director of Financial Aid Corrective Action Plan: The Financial Aid Director recently completed R2T4 process training with the Controller. This added expertise will enhance the secondary review process, providing an independent assessment by a reviewer not involved in daily operations. This additional oversight will strengthen quality control through sampled calculation reviews. Furthermore, expanded attendance and withdrawal reports will support comprehensive control processes for this cluster. Anticipated Completion Date: Commenced December 1, 2024

View Audit 331672

Finding 513740 (2024-004)

Significant Deficiency 2024

Oklahoma Panhandle State University

OK

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 ...

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar reviews an error report each month, resolves the errors, and then submits the report to NSLDS. NSLDS responds with an error resolution report, which is then used to resolve any further issues, and confirm the final reporting to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Erin Moore and Dasha Smith Planned completion date for corrective action plan: December 15, 2024

View Audit 331630

Finding 513739 (2024-003)

Material Weakness 2024

Oklahoma Panhandle State University

OK

Questioned Costs Special Tests & Provisions Student Financial Aid § 200.303

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.269Recommendation: We recommend that the Univer...

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.269Recommendation: We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid will update the unofficial withdrawal process with successful completion definition to be inclusive of requiring a passing grade. Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: December, 15 2024

View Audit 331630 Questioned Costs: $1

Finding 513738 (2024-002)

Significant Deficiency 2024

Oklahoma Panhandle State University

OK

Eligibility Procurement, Suspension & Debarment Student Financial Aid § 200.303

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University...

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University review internal controls related to Eligibility and ensure appropriate checks are in place to identify students who are not meeting the University's qualitative and quantitative criteria for maintaining SAP. Explanation of disagreement with audit finding: There is no disagreement with the audit finding . Action taken in response to finding: The Registrar's Office procedure will be to convert clock hours to credit hours to avoid this situation moving forward. Name(s) of the contact person(s) responsible for corrective action: Erin Moore and Dasha Smith Planned completion date for corrective action plan: December 15, 2024

View Audit 331630

Finding 513700 (2024-002)

Significant Deficiency 2024

City Colleges of Chicago

IL

Student Financial Aid Subrecipient Monitoring Reporting § 200.303

Finding 2024-002 – Enrollment Reporting Condition • For one out of sixty students tested (2%) who withdrew from City Colleges, the students’ withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution’s records. Also, th...

Finding 2024-002 – Enrollment Reporting Condition • For one out of sixty students tested (2%) who withdrew from City Colleges, the students’ withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution’s records. Also, the student’s program level withdrawal was not reported to NSLDS within 60 days. • For one out of sixty students tested (2%) who withdrew from City Colleges, the student’s withdrawal date reported to the NSLDS for campus level was not reported to NSLDS within 60 days. • For two out of sixty students tested (3%) who withdrew from City Colleges were not reported to NSLDS within 60 days. Cause CCC sends enrollment files of all students to National Student Clearinghouse (NSC) monthly, who then reports CCC enrollment data to National Student Loan Data System (NSLDS). It was discovered that two of the errors occurred due to an update in NSLDS and CCC was not aware the update caused missing files. In the other instances files were sent in late February, but not corrected within NSC until March 5th thus, it missed the beginning of the March roster. Corrective Action Taken or Planned CCC will work with NSC to monitor future updates and ensure files are accurately shared with NSLDS. Records, Financial Aid, Decision Support and OIT continue to meet bi-weekly to review and update the enrollment reporting logic to ensure the dates for student enrollment actions align at the campus level and the program level. In addition, the compliance team will monitor updates and announcements from NSC regarding file errors to ensure timely updates are submitted. Contact Person: Laura Clark, Associate Vice Chancellor, Academic Systems and Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 20, 2024

View Audit 331604

Finding 513661 (2024-002)

Significant Deficiency 2024

Vanguard University of Southern California and Affiliates

CA

Student Financial Aid Subrecipient Monitoring Reporting

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: An undergraduate student in a year-round program was reported to National Student Clearinghouse (NSC) as a student for whom summer term was nonst...

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: An undergraduate student in a year-round program was reported to National Student Clearinghouse (NSC) as a student for whom summer term was nonstandard. Non-standard summer term students are not reported to NSC over summer if they are not enrolled. Since this student was in a year-round program, the student should have been reported with summer as a standard term. Based on Vanguard’s NSC transmission schedule, had this student’s NSC Branch been classified correctly, the student would have been in a NSC transmission standard term data file and reported within 30 days of the enrollment adjustment. Annually, the Registrar’s Office will review all programs to ensure that year-round program students are reported to NSC with summer as a standard term. The assistant registrar who is responsible for both NSC reporting and updating program degree audits will manage this process with the dean of academic records oversight. The Registrar’s Office will create a column in the annual degree audit log that indicates standard/non-standard classification has been properly determined and set up correctly in the student information system for accurate reporting to NSC. A sample set of students within each NSC transmission will be checked following transmission in NSC by the Registrar’s Office and NSLDS by the Financial Aid Office to ensure that enrollment status is accurate. Name of Contact Person: Julie Cowen, Dean of Academic Records, 714-662-5204 Projected Completion Date: Program review for standard/non-standard classification for 2024-25 was completed on October 28, 2024 and will be completed annually in March-April beginning in 2025.

View Audit 331568

Finding 513656 (2024-001)

Significant Deficiency 2024

Vanguard University of Southern California and Affiliates

CA

Special Tests & Provisions Student Financial Aid Significant Deficiency

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV Funds: Significant Deficiency in Internal Controls Over Compliance Corrective Action Plan: A traditional undergraduate who withdrew did not have an R2T4 calculation completed within 30 days of withdrawal and federal funding was not...

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV Funds: Significant Deficiency in Internal Controls Over Compliance Corrective Action Plan: A traditional undergraduate who withdrew did not have an R2T4 calculation completed within 30 days of withdrawal and federal funding was not returned within 45 days of withdrawal. The withdrawal process by the student and academic staff was not completed according to process or timeframe. The course deregistration and withdrawal process for a traditional undergraduate student did not occur following standard procedures or timeframe. The Registrar’s Office entered two different course deregistration dates, within the two-week add/drop period, into the student information system and the withdrawal was entered nearly 60 days after the first day of class. The withdrawal and leave of absence reports generated daily and enrollment adjustment report generated weekly had inadequate queries to catch this complicated course deregistration and withdrawal situation to trigger timely R2T4 calculation and return of federal funding. Following this finding, the Financial Aid Office identified the reporting deficiencies and started dialog with the Registrar’s Office and Information Technology regarding student information system screens and fields being used by the Registrar’s Office that need to be adjusted on the reports. The Registrar’s Office understands the interdependency between its office and the Financial Aid Office with regards to enrollment adjustments and completing an R2T4 calculation, returning federal funding, monitoring Common Origination and Disbursement transmission and any necessary communication with students. With daily and weekly monitoring of said reports, and the Registrar’s Office proactively notifying the Financial Aid Office of any enrollment adjustments that are nearing the R2T4 deadlines rather than solely relying on reports, the Financial Aid Office will be positioned to be compliant with the federal deadlines. The Financial Aid Office will begin a two-person review of calculation and funding return and a recorded acknowledgement of such. Name of Contact Person: Kim Johnson, Vice President for Enrollment Management, 714-966-5415 Projected Completion Date: Review of all fall 2024 enrollment adjustment/withdrawal/leave of absence students after the first day of class (August 26, 2024) will be done by the vice president for enrollment management (serving as director of financial aid) and assistant director during November 2024. Going forward, said two-person review will be done daily by the assistant director and at a minimum biweekly by a senior manager.

View Audit 331568

Finding 513630 (2024-001)

Material Weakness 2024

Clarke University of Dubuque, Iowa

IA

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

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans ‐ 2023/2024 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program ‐ 2023/2024 P063P201430 Special Tests & Provisio...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans ‐ 2023/2024 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program ‐ 2023/2024 P063P201430 Special Tests & Provisions:– Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary: One instance was identified where there was no documented return of Title IV calculation, and fourteen instances were identified where there was no documented review of the return of Title IV calculation. Responsible Individuals: Robert Hoover, Director of Financial Aid and Sylma Fernandez, Assistant Director of Financial Aid Corrective Action Plan: The Financial Aid Director recently completed R2T4 process training with the Controller. This added expertise will enhance the secondary review process, providing an independent assessment by a reviewer not involved in daily operations. This additional oversight will strengthen quality control through sampled calculation reviews. Furthermore, expanded attendance and withdrawal reports will support comprehensive control processes for this cluster. Anticipated Completion Date: Commenced December 1, 2024

View Audit 331542

Finding 513617 (2024-002)

Material Weakness 2024

Calvary University

MO

Student Financial Aid Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment

Condition Found: The University has an adequate Satisfactory Academic Progress policy. Student GPAs and completion rates are reviewed at the end of each academic year. However, the University is not informing students when they are placed on financial aid suspension and how to appeal the decision. C...

Condition Found: The University has an adequate Satisfactory Academic Progress policy. Student GPAs and completion rates are reviewed at the end of each academic year. However, the University is not informing students when they are placed on financial aid suspension and how to appeal the decision. Corrective Action Plan: Management agrees with the auditors’ finding and their recommendation. The Business Office and the Director of Financial Aid is in the process of creating a Financial Aid Suspension Letter to notify students of the financial aid ramifications of being placed on financial aid suspension. Anticipated Completion Date: The corrective action will be completed by December 31, 2024. Contact Person: Tasha Young, CFO 816-425-6151

View Audit 331527

Finding 513616 (2024-001)

Material Weakness 2024

Calvary University

MO

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Condition Found: The bi-monthly National Student Loan Database System (“NSLDS”) Enrollment Reporting Summary Reports were not updated and returned to NSLDS during the year ended June 30, 2024. Therefore, student enrollment status changes were not reported timely to NSLDS. Corrective Action Plan: Man...

Condition Found: The bi-monthly National Student Loan Database System (“NSLDS”) Enrollment Reporting Summary Reports were not updated and returned to NSLDS during the year ended June 30, 2024. Therefore, student enrollment status changes were not reported timely to NSLDS. Corrective Action Plan: Management agrees with the auditors’ finding and their recommendation. The Director of Financial Aid or business office staff will update the enrollment status for all students who obtained Federal Direct Student Loans from the University. The University will review its contract with their third-party financial aid administrator. The University will update their policies and procedures as needed. Anticipated Completion Date: The corrective action will be completed by December 31, 2024. Contact Person: Tasha Young, CFO 816-425-6151

View Audit 331527

Finding 513610 (2024-007)

Significant Deficiency 2024

Cleveland State University

OH

Internal Control / Segregation of Duties Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Name of the contact person responsible for corrective actions planned: Rachel Schmidt Financial Aid Director Cleveland State University 2121 Euclid Avenue, UN 402 Cleveland, OH 44115 Phone: 216.687.5594 E-mail: r.m.schmidt@csuohio.edu Corrective actions planned: During the audit of Perkins Loan fil...

Name of the contact person responsible for corrective actions planned: Rachel Schmidt Financial Aid Director Cleveland State University 2121 Euclid Avenue, UN 402 Cleveland, OH 44115 Phone: 216.687.5594 E-mail: r.m.schmidt@csuohio.edu Corrective actions planned: During the audit of Perkins Loan files, it was identified that 5 out of the 25 files tested did not contain a signed Perkins Loan form. Management understands the recommendation to review and strengthen its procedures for collecting and retaining Perkins Loan forms and the need to retain the records of former students. While we are certain that the required documentation exists or existed at one time, the passage of time and lack of digital backups impaired our ability to produce the documents. Since the loans related to the missing documents are currently in repayment status, we feel that provides assurance the former students did sign the loan agreement. However, we understand the need to retain all critical forms for our students. Completion date: November 2024

View Audit 331516

Finding 513576 (2024-002)

Material Weakness 2024

Woodbury University

CA

Student Financial Aid Subrecipient Monitoring Material Weakness

Woodbury University Corrective Action Plan For the Year Ended June 30, 2024 Agency: U.S. Department of Education Name of Federal Program or Cluster: Student financial assistance cluster Award Year: 2023-2024 Finding 2024-002 – Special Tests and Provisions – Enrollment Reporting – Material Weakness ...

Woodbury University Corrective Action Plan For the Year Ended June 30, 2024 Agency: U.S. Department of Education Name of Federal Program or Cluster: Student financial assistance cluster Award Year: 2023-2024 Finding 2024-002 – Special Tests and Provisions – Enrollment Reporting – Material Weakness in Internal Control Over Compliance Conditions: From a system generated population of 119 students who received federal aid and either graduated, withdrew, or changed their permanent address during the year ended June 30, 2024, auditors selected a sample of 17 students who received direct loans. The enrollment information and withdrawal or graduation date per the Woodbury University’s records were compared to the information reported to NSLDS in order to determine if status changes were reported accurately and within the required timeframes. Of the 17 students selected for testing, 17 were not reported to the NSLDS within the required timeframe and had an incorrect status reported to the NSLDS. Corrective Action Plan: If the student is planning to leave the University. Students must withdraw from all classes before the withdraw date. Also, the students must circulate their form to the listed departments for a signature. The issue is something this was completed by email with several forms for the same student. We will work with Redlands to create a Soft Doc/ electronic withdraw form which can be completed by the student on line. This form will be accessible to the offices listed on the form paper. Also, this will aid in the Registrar's Office and Financial Aid to have more accurate record of the students who have completed the withdraw process. Name of Contact Person: Verletta Jackson, Registrar, (818) 252-5277 Projected Completion Date: Spring 2025

View Audit 331458

Finding 513571 (2024-001)

None 2024

Maharishi International University

IA

Student Financial Aid

The University will review and update its internal procedures and controls for handling credit balances to ensure that future Title IV credit balances are disbursed to students within the 14 day window.

View Audit 331428

Corrective Action Plans

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