Corrective Action Plans

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To ensure compliance with the 60-day enrollment update requirement, the Registrar's Office staff will manually enter any withdrawals and leaves of absence into the National Student Clearinghouse (NSC) website upon processing them in Coileague. Using the Student Look Up tool on the NSC website, they ...
To ensure compliance with the 60-day enrollment update requirement, the Registrar's Office staff will manually enter any withdrawals and leaves of absence into the National Student Clearinghouse (NSC) website upon processing them in Coileague. Using the Student Look Up tool on the NSC website, they will update the student's status along with the status start date. Additionally, the confirmation email from the NSC, which verifies that the enrollment update has been processed, will be saved in the student's record.
Finding 540930 (2024-001)
Significant Deficiency 2024
Federal Perkins Loan Program, ALN 84.038; Grant period—Year ended June 30, 2024 Condition: There was lack of documentation related to notices for loans paid off for eight out of ten students tested. Criteria: According to §674.19(e)(4)(iii), after the loan obligation is satisfied, the institution ...
Federal Perkins Loan Program, ALN 84.038; Grant period—Year ended June 30, 2024 Condition: There was lack of documentation related to notices for loans paid off for eight out of ten students tested. Criteria: According to §674.19(e)(4)(iii), after the loan obligation is satisfied, the institution shall return the original or a true and exact copy of the note marked "paid in full" to the borrower, or otherwise notify the borrower in writing that the loan is paid in full, and retain a copy for the prescribed period. Cause: The College was unable to locate the communication sent to certain students of loan payoff as a result of staff turnover. Effect: Certain documentation for notification of loan satisfaction could not be provided. Context: During the compliance audit testing of ALN 84.038, it was determined that documentation to confirm delivery of loan satisfaction notices could not be provided for certain students selected for testing. Recommendation: We recommend all required documentation be backed up to support compliance with certain requirements. View of Responsible Officials and Planned Corrective Action: The College is currently working within the financial aid department to make sure the College has support for all communications.
The following was noted during the audit of Federal programs in accordance with UMB Uniform Guidance. Management proposes the following Corrective Action Plan: Finding 2024-001: Notification of Title IV loan disbursements and the borrower’s right to cancel all or part of the loan was not provided ap...
The following was noted during the audit of Federal programs in accordance with UMB Uniform Guidance. Management proposes the following Corrective Action Plan: Finding 2024-001: Notification of Title IV loan disbursements and the borrower’s right to cancel all or part of the loan was not provided appropriately. Management’s View The University agrees with this finding. Two separate issues contributed to the finding. Vanderbilt identified both issues internally and implemented immediate measures to mitigate the impact to students ensuring all notifications are properly delivered prospectively. First, human error, primarily due to incomplete documentation and a new staff member running the process, caused the issue of some loan notifications not being sent. However, the University implemented quality control steps in July of 2024 to resolve the issue. These steps included providing additional training to the staff member, correcting the documentation, and updating the scheduled run control of the process to correctly identify all students with any federal loan disbursement. In addition, the University implemented a quality control process creating a daily report, generated from multiple PeopleSoft queries, that identifies any students who have a federal loan either initially or subsequently disbursed who are missing the required notifications. Second, a data merge issue combined with larger than usual volumes of students receiving loan disbursements caused a processing error resulting in blank information on loan notifications. The initial run in the spring semester included a larger than usual number of students with loan disbursements who shared the same start date, whereas in comparison fall start dates generally are more varied. The University identified this issue in January through manual reviews and manually sent subsequent notifications to affected students. Corrective Action Plan As a corrective measure, Vanderbilt took the following actions to address the identified issues: 1. Reviewed and updated documentation related to the Peoplesoft notification process to ensure completeness and accuracy. 2. Provided additional staff training to the personnel responsible for running the notifications process within Peoplesoft. 3. Created a quality review process to review a daily report from Peoplesoft that identifies any student with a federal loan disbursement that is missing required notifications. 4. Updated queries related to communication generation to run more efficiently. 5. Modified the communication generation process to run nightly instead of weekly to ensure data limits are appropriate to allow the process to run completely and accurately. 6. Created a quality review process to review a weekly report from PeopleSoft to timely identify any missing information in student notifications. Vanderbilt fully implemented the steps above by September 2024. For follow-up questions and information, please contact Brent Tener, Assistant Provost and Executive Director of Student Financial Aid and Scholarships at Vanderbilt University.
Finding 2024-002: Incomplete Verification Tested sixty-three files and an application selected for verification did not match supporting documentation for one student. Comments on Finding and Recommendation(s): The Institute agrees with the finding and Auditor's recommendation. Actions Taken or Plan...
Finding 2024-002: Incomplete Verification Tested sixty-three files and an application selected for verification did not match supporting documentation for one student. Comments on Finding and Recommendation(s): The Institute agrees with the finding and Auditor's recommendation. Actions Taken or Planned: The school has implemented an internal check and balance to ensure that all files have the documentation required. The school has also partnered with a third-party servicer that will also be auditing the documentation needed to complete verification of student files.
View Audit 350416 Questioned Costs: $1
Finding 2024-001: Incorrect Pell Grants Tested sixty-three files, fifty-four of which were Pell Grant recipients, and four students received Pell grants in excess of their allowed amounts and two students did not receive the full amount of their allowed Pell grants. Comments on Finding and Recommend...
Finding 2024-001: Incorrect Pell Grants Tested sixty-three files, fifty-four of which were Pell Grant recipients, and four students received Pell grants in excess of their allowed amounts and two students did not receive the full amount of their allowed Pell grants. Comments on Finding and Recommendation(s): The Institute agrees with the finding and Auditor's recommendation. Actions Taken or Planned: The school has revised our method of requesting aid and the enrollment status of each student will be verified individually prior to requesting Pell. We have also removed FA administrator (effective 12/2023) and third-party servicer from their role (effective 4/2024). We will be refunding $2,910 to the Department of Education and crediting $1,053 to the affected student accounts.
View Audit 350416 Questioned Costs: $1
Finding 540698 (2024-003)
Significant Deficiency 2024
2024-003 Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants – Assistance Listing No. 84.007 Federal Work-Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Loans – Assistance Listing No. 84.268...
2024-003 Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants – Assistance Listing No. 84.007 Federal Work-Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Loans – Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants– Assistance Listing No. 84.379 Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The McKendree University Financial Aid Office has an automated daily process for notifying COD of all federal aid disbursements after a disbursement is made to a student’s account. This process also includes a step for checking the COD website for any rejected files to confirm that students were correctly reported within a day of loan and TEACH grant disbursements occurring, well within the 15-day required notification time frame. Name(s) of the contact person(s) responsible for corrective action: Patrick Michael, Director of Financial Aid Planned completion date for corrective action plan: June 30, 2025
The College will be forgiving the outstanding balance for all students that the original Perkins loan promissory note was unable to be located, eliminating the requirement to have the promissory note on file.
The College will be forgiving the outstanding balance for all students that the original Perkins loan promissory note was unable to be located, eliminating the requirement to have the promissory note on file.
Finding 540601 (2024-001)
Significant Deficiency 2024
Corrective Action Plan Year-end June 30, 2024 The following finding was noted during the audit of Federal programs in accordance with 2 CFR 200. Management of Syracuse University agrees with the finding and proposes the following Corrective Action Plan. Finding Number 2024-001: Enrollment Reporting ...
Corrective Action Plan Year-end June 30, 2024 The following finding was noted during the audit of Federal programs in accordance with 2 CFR 200. Management of Syracuse University agrees with the finding and proposes the following Corrective Action Plan. Finding Number 2024-001: Enrollment Reporting Corrective Action Plan: The University has identified a remediation plan in response to the finding, including the following: 1. Immediate Mitigations (within 90 Days): a. The Office of the Registrar and Office of Financial Aid and Scholarship programs will formalize a quarterly check-in meeting with multiple levels of stakeholders to ensure that our enrollment reporting process is complying and to address any new concerns that may arise. These check-in meetings have been scheduled and begin on March 26, 2025. 2. Long-Term Mitigations (within 12 months) a. The Office of the Registrar will work with Information Technology Services colleagues to implement a Graduates Only Enrollment file for multi-career students to increase the quantity of records that can be automatically processed. This work will be made productional by February 1, 2026 i. This will reduce our error rate and decrease the volume of records requiring manual review, allowing for more focused attention on the most complicated scenarios. Responsible individuals: Michele B Sipley, Executive Director of Financial Aid Kelly Campbell, University Registrar
Finding 2024-001 Federal Agency: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 Federal Award Year: Funding periods between July 1, 2023 through June 30, 2024 Compliance Requirement: Eligibility Finding Type: Noncompliance and Signi...
Finding 2024-001 Federal Agency: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 Federal Award Year: Funding periods between July 1, 2023 through June 30, 2024 Compliance Requirement: Eligibility Finding Type: Noncompliance and Significant Deficiency The School of Dental Medicine did not have a report to identify students with a federal loan aggregate related issue. The Office of Admissions and Financial Aid had a report for students in the undergraduate and graduate careers (excluding the Dental Medicine professional Primary Academic Program). The Office of Admissions and Financial Aid added the School of Dental Medicine staff as a recipient on this report to assist them in identifying students with an ISIR code indicating students that are approaching or have already exceeded the Federal Direct Loan aggregate limits for review. Since September 2024, the School of Dental Medicine has been receiving and reviewing the Aggregate Overpay Checklist report. Name of the contact person: Michelle Jackson Completion date: Already completed, September 2024
View Audit 350369 Questioned Costs: $1
The correc􀆟ve ac􀆟on plan is as follows: Anna L. Stovall, with the assistance of the Registrar’s office, will review the status of graduated students during the first two weeks in June 2025, to ensure their effec􀆟ve graduate date is accurately reported. Further, those students who have informed David...
The correc􀆟ve ac􀆟on plan is as follows: Anna L. Stovall, with the assistance of the Registrar’s office, will review the status of graduated students during the first two weeks in June 2025, to ensure their effec􀆟ve graduate date is accurately reported. Further, those students who have informed Davidson College that they are on a leave of absence will also be reviewed in the coming weeks. It is an􀆟cipated that these ac􀆟vi􀆟es will be completed not later than June 30, 2025. These ac􀆟ons are in response to audit finding 2024-001.
Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SOU acknowledges at the time of the audit; management could not ascertain whether the contract with BankMobile was uploaded to the Department of Education Contract p...
Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SOU acknowledges at the time of the audit; management could not ascertain whether the contract with BankMobile was uploaded to the Department of Education Contract portal as there is no repository or database available to schools. This submission was completed on March 17, 2025 and documentation was retained to support the submission. Name(s) of the contact person(s) responsible for corrective action: Daniel M. Tramuta, Interim Director of Financial Aid Planned completion date for corrective action plan: March 2025
Recommendation: We recommend the Institute review its policies and procedures around sending entrance information to students to ensure students are receiving proper counseling and ensure entrance counseling is documented before loans disbursements are made. Explanation of disagreement with audit f...
Recommendation: We recommend the Institute review its policies and procedures around sending entrance information to students to ensure students are receiving proper counseling and ensure entrance counseling is documented before loans disbursements are made. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SOU will review its policies and procedures for Direct Loan entrance counseling to ensure all students, including GRAD PLUS loan recipients, have completed their entrance counseling or previously completed counseling is retained within the student information system. Name(s) of the contact person(s) responsible for corrective action: Daniel M. Tramuta, Interim Director of Financial Aid Planned completion date for corrective action plan: April 2025
View Audit 350358 Questioned Costs: $1
Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: Ther...
Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Student Records Specialist and University Registrar will be reviewing and revising policies and procedures related to enrollment reporting with the Clearinghouse data which then feeds into NSLDS. SOU will review calendar preparations, data collection, data submission and confirmation, error handling, file preparation documentation/instructions to identify breakdown in the process that lead to noncompliant reporting. SOU will increase monitoring of Clearinghouse data and also reach out to Clearinghouse to identify reports/tools that can assist with accurate and timely reporting. Name(s) of the contact person(s) responsible for corrective action: Rose Reinhart, Interim Registrar Planned completion date for corrective action plan: June 2025
Finding 2024-002 Enrollment Reporting: The Office of the Registrar acknowledges the finding related to delayed status reporting and agrees that there were instances where student information was not transmitted within the required timeframe. Although a process is now in place to support more consi...
Finding 2024-002 Enrollment Reporting: The Office of the Registrar acknowledges the finding related to delayed status reporting and agrees that there were instances where student information was not transmitted within the required timeframe. Although a process is now in place to support more consistent and timely submissions, earlier delays were influenced by staffing changes and operational challenges. To ensure ongoing compliance, the Office of the Registrar has implemented an updated submission schedule that aligns with federal reporting expectations. Enrollment and graduation data are now submitted regularly and any reporting errors are corrected and resubmitted within the 10-day recommended timeframe. These steps are part of our ongoing efforts to maintain data accuracy and comply with institutional and regulatory standards. Implementation Date: August 2025 Person Responsible: Brianna Mendez, Student Data Specialist, Office of the Registrar
inding 2024-001 – Reporting: The Financial Aid office concurs with the audit of Pell 15-day reporting finding. The compliance is clearly stated the timeframe to send an original Pell Grant disbursement to COD is within 15 days of the date of disbursement. We also understand we have the permission,...
inding 2024-001 – Reporting: The Financial Aid office concurs with the audit of Pell 15-day reporting finding. The compliance is clearly stated the timeframe to send an original Pell Grant disbursement to COD is within 15 days of the date of disbursement. We also understand we have the permission, as stated per Federal Regulations, to go back into the account and make an adjustment as needed. This allows us to change the disbursement to make a correction. We have worked with our software vender Ellucian Banner to create a process that will solve this issue to ensure Pell Grants are originated on COD thus allowing the disbursements to be sent within the 15-day compliance timeframe. We will continue to monitor the Pell Grants to ensure any issues get resolved, if any noted, in a timely manner. Implementation Date: August 2025 Person Responsible: Jesse Marquez Associate Director and Information Specialist of Financial Aid Julie Aldama Financial Aid Director
II. Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material weakness): We observed the following conditions in connection with our testing of the TRIO programs: (a) UB Eligibility Test: Of the 17 students selected for testing, one (1) student’s citizenship could not b...
II. Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material weakness): We observed the following conditions in connection with our testing of the TRIO programs: (a) UB Eligibility Test: Of the 17 students selected for testing, one (1) student’s citizenship could not be determined, two (2) students did not provide any income information on the application, ten (10) students did not provide tax returns to verify low income as reported. (b) ETS Eligibility Test: Of the 17 students selected for testing, seven (7) students' citizenship status could not be determined, documentation to support enrollment status was not provided for 17 students, one (1) student did not have any information uploaded, and one (1) student has a birthdate discrepancy. (c) Educational Opportunity Center (EOC) Eligibility Test: Of the 17 participants selected for EOC testing, 17 did not have an enrollment agreement, acceptance letter, nor tax documents uploaded to adequately test the attributes, and one (1) student did not have a signature page for the EOC application. Auditor's Recommendation – We recommend the College ensure that all required documentation is submitted prior to determining the participants' eligibility. Corrective Action – Tougaloo College Administration understands the importance of federal compliance. The Vice President for Strategic Initiatives & Social Justice has direct management oversight of the TRIO programs. The lack of internal controls related to UB Eligibility Test, ETS Eligibility Test, and EOC Eligibility Test (verification of citizenship, income information, tax refunds, documentation of enrollment status, enrollment agreement, and birthdate verification), a non-recurring finding, were largely caused by a high degree of staff turnover and lack of experience in the front-line staff directly responsible for these controls. Although it has proven difficult to hire and retain highly qualified staff due to higher salaries paid by other institutions for similar positions in our market, the Executive Director of the TRIO programs and leadership team has implemented the following actions to correct the findings: 1. Continue to recruit and develop internal protocols to more fully retain highly qualified personnel. 2. Continue to train staff and increase staff training specific to reviewing the proper documentation required for attending the programs. 3. Include an additional level of early review by the Executive Director and other senior program staff to verify compliance at multiple stages of program involvement by students, including when students are initially recruited and enrolled. 4. Internal federal compliance testing will be a required criteria for the staff annual evaluations reviewed by the Executive Director of TRIO programs and the Vice President for Strategic Initiatives & Social Justice.
I. Finding 2024-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (material weakness): 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) 11 out of 60 st...
I. Finding 2024-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (material weakness): 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) 11 out of 60 students did not meet Satisfactory Academic Progress (SAP) for the academic year. The College did not provide supporting documentation for successful appeals and allowed the students to receive Title IV funding. 34 CFR 668.34. Questioned costs for this finding is $180,794. 2) Nine (9) of the 10 students tested for Federal Work-Study Payroll had missing and/or incomplete timesheets. 34 CFR Part 675. 3) Six (6) of the 10 students tested for withdrawals and the return of Title IV funds did not have their Title IV program funds returned within the 45-day requirement. HEA, Section 484B & 34 CFR 668.22. 4) Entrance and exit counseling documentation was not provided for first time borrowers, withdrawn students or graduated students. 34 CFR 685.304. 5) Cost of Attendance Budgets to determine students unmet need were not provided by the College. 34 CFR 685.102(b). 6) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations Report and Application to Participate (FISAP) for Federal Pell Grant, Federal SEOG and Federal Work-Study. 7) The College did not reconcile all Title IV programs between the Office of Financial Aid and the Business Office including Federal Pell Grant, Federal SEOG, Federal Work-Study and Federal Direct Loans. CFR 685.300(b)(5). Auditor's Recommendation – The College should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of processes, and policies and procedures are being updated and adhered to for compliance purposes. Auditor's Recommendation – The College should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of processes, and policies and procedures are being updated and adhered to for compliance purposes. Corrective Action – Tougaloo College Administration understands the importance of federal compliance. The collective knowledge of others within the Division of Finance and Administration reinforces the expertise of the four financial aid staff members. The Vice President of Finance and Administration, in collaboration with the Vice President for Enrollment and Student Services, who has direct oversight of the financial aid department, has implemented professional development targeted training on the continuous changes in Title IV program management. In addition to addressing/paying the questioned costs found with improper documentation of Satisfactory Academic Progress with USDE, the following allows for corrective actions while continuing to engage with the Title IV student financial aid programs: 1. Financial Aid team members become certified in the enterprise resource program module, specific to financial aid. 2. Annually, one or more staff members attend the national conference for student aid administrators, which focuses on deepening understanding of federal regulations, exploring new legislation enacted by Congress, gaining practical experience with student loan data systems, and networking with industry peers who offer support identifying and effectively addressing challenges associated with financial aid operations. 3. Attend monthly and quarterly training via knowledge base webinars on: Satisfactory Academic Progress (SAP), Work-study process for students and staff, student loan process, the return of Title IV funds, and reconciling expenditures with the Business Office. 4. Utilize additional resources from the U.S. Department of Education’s Minority-Serving and Under-Resourced Schools Division for administering Title VI Aid.
View Audit 350319 Questioned Costs: $1
1. Implement new communication channels to align process to NSLDS and the USDoE.  Engage with NSLDS: Requested an access token for the data manager to monitor and reconcile data submitted.  Reach out to NSLDS to coordinate new reconciliation reports out of NSLDS database. 2. Training  Maintain su...
1. Implement new communication channels to align process to NSLDS and the USDoE.  Engage with NSLDS: Requested an access token for the data manager to monitor and reconcile data submitted.  Reach out to NSLDS to coordinate new reconciliation reports out of NSLDS database. 2. Training  Maintain sustained training and preparation for the staff. 3. Implement a weekly review process to double­check the entries for changes in enrollment reporting in NSLDS.  Implement a Document Changes and Actions Log: Keep detailed records of all changes made to procedures and actions taken to address the audit findings. This documentation can be useful for future reviews.  The Registrar will assure that all changes (LOA, withdrawals, re­ entries, and reclassifications, completions, graduations) are entered weekly and documented across all databases (NSLDS, Jenzabar student record, SRS, others as applicable).
The University has an automated process in place to disburse aid daily. That process is set to stop on a certain day before the University’s scheduled Winter Break to allow the refund processing team time to generate and distribute refunds within the allotted time and maintain compliance with relate...
The University has an automated process in place to disburse aid daily. That process is set to stop on a certain day before the University’s scheduled Winter Break to allow the refund processing team time to generate and distribute refunds within the allotted time and maintain compliance with related regulations despite the University’s scheduled closure. According to established procedures, the process was stopped as scheduled. However, one of the University’s Financial Aid Counselors manually authorized and disbursed aid for a small number of students after the process was halted for the semester because they were unaware of the reason why aid was not disbursing, and they were attempting to help students who were calling the Financial Aid office. Once management became aware of this issue, the Director of Financial Aid immediately approached the staff member and explained the reason the University stopped making disbursements. The Director instructed the team member to not override these established controls and explained the importance of adhering to the policies in place. The staff member acknowledged that they understood the consequences of their actions and the need to adhere to policies. In the future, the University will take extra steps to communicate with all team members when this control is initiated prior to Winter Break to ensure collective understanding of the reason for pausing disbursement. Person(s) Responsible: Director of Financial Aid (disbursement timing). Controller & Associate Vice President (payment timing). Targeted Correction Date: June 30, 2025.
This issue was initially identified by the University through HPU’s internal monitoring processes. The cause was significant staff turnover within a 6-month period (including the resignation of the Director of Financial Aid). The difficulties of temporarily reduced staffing and loss of institutional...
This issue was initially identified by the University through HPU’s internal monitoring processes. The cause was significant staff turnover within a 6-month period (including the resignation of the Director of Financial Aid). The difficulties of temporarily reduced staffing and loss of institutional knowledge were compounded by the challenges brought by the FAFSA Simplification Act, which required many changes, placing an additional burden on a strained team. Although the University attempted to adhere to its policies and procedures to ensure that R2T4 is processed within the allotted time, the team did not succeed in completing this function. The University replaced key staff, recruited a new Director, and shifted responsibilities so that a specific staff member is responsible for R2T4 processing. These changes have enabled the University to resume processing R2T4 timely, as was accomplished in previous years. Person(s) Responsible: Director of Financial Aid. Targeted Correction Date: January 31, 2025. This issue is resolved.
The Information Security Officer has developed a comprehensive project plan to implement the core 9 elements as listed under FTC Safeguards. The plan is backed by HPU’s 3rd party risk assessment conducted in November of 2024. The addition of a new hire and a part-time resource has facilitated signif...
The Information Security Officer has developed a comprehensive project plan to implement the core 9 elements as listed under FTC Safeguards. The plan is backed by HPU’s 3rd party risk assessment conducted in November of 2024. The addition of a new hire and a part-time resource has facilitated significant progress. Budget for necessary tools, software, and services such as penetration testing are being actively quoted for review by the Budget Office and CFO for both current and future fiscal years. Checkpoints have been established every two weeks to review and confirm substantial progress towards meeting all requirements and address any barriers or setbacks that may occur. The Vice President of Operations and CIO will review the progress support efforts to meet the requirements and targeted delivery date. The HPU Cybersecurity Committee will be provided with the 2024 Risk Assessment and the Information Security Program documentation and policies for both initial and ongoing review of the programs with the objective to further strengthen the program beyond minimum requirement. Person(s) Responsible: Information Security Officer; Vice President of Operations and Chief Information Officer. Targeted Correction Date: June 30, 2025.
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. CWS recognizes that Licensing case files from neighbor islands (Maui, West Hawaii, and Kauai) came late or not at all, and this lack of ability to review the records significantly contribute...
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. CWS recognizes that Licensing case files from neighbor islands (Maui, West Hawaii, and Kauai) came late or not at all, and this lack of ability to review the records significantly contributed to the errors. Moving forward, CWS will ensure easier records identification by geographical location and begin the neighbor island’s audits first, allowing extra time for records travel to review site. CWS also notes that additional communication and information sharing with auditors would have been helpful to ensure understanding of expectations prior to on site audit. The communications requested would resemble a pre audit information sharing call, an on site audit entry meeting with key agency staff, and an audit exit conference to discuss findings before the final report is generated. Corrective Action Taken or Planned: 1. CWS staff will be informed of the audit findings and corrective action plan, emphasizing the importance of: A. Providing requested records in advance of the audit, B. Diligent compliance with policies and procedures, C. Supervisor coaching, support and review of records/documents for completeness, D. The impact of individual unit records maintenance performance on the outcome of the audit and this corrective action plan. 2. Case specific audit findings and corrective actions taken will be noted in each record where there was a finding. Staff will: A. Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated and ensuring filed in eligibility record. B. Locate or reprint and file missing “Certificate of Approvals.” C. Locate missing clearances in records not provided for review or re-run them if not located in records reviewed. Please note: Not all clearances are secured prior to placement; FBI clearances come later and are NOT required prior to placement in a “provisionally licensed” home. D. Administrators to work with courts to ensure court orders contain the required language and are secured in a timely fashion. i. Secure missing termination of parental rights order. ii. Secure court order supporting “reasonable efforts.” iii. Secure missing police protective custody documentation or voluntary foster custody agreement for three cases. E. For young person(s) in Imua Kakou (“IK”) who turned 18 while in care. i. CWS will secure a letter for the record, from the school that the young person is attending, which notes when the young person is expected to graduate. ii. Work with IK providers and IK liaison to make sure logs and meeting minutes are in SHAKA. iii. Document the reason for continuation of monthly subsidy payments after youth turned 18 or discontinue payment. 3. CWS has identified the Eligibility Unit (“FPPEU”) record as the primary record for audits with the Licensing record and other case files as secondary. 4. Unit staffs (Licensing, CWS and FPPEU) who manage cases identified with errors in this audit will be retrained, ensuring familiarity with grant requirements and related policies and procedures. A. The FPPEU Administrator and supervisors will review the eligibility unit record checklist and ensure use of checklist will lead to a complete record containing all required documentation. B. FPPEU staff will review error records identified in this audit, following checklist and secure missing documentation, update inaccurate information and verify that all necessary documentation is present. i. Staff may be given individual training or coaching/supervisory support to correctly complete documentation. ii. Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated. iii. Case specific audit findings and corrective actions taken will be noted in each record where there was a finding. C. The Licensing Unit Section Administrator and supervisors will review error records identified in this audit, secure missing documentation, update inaccurate information and verify that all necessary documentation is present. i. Staff will be given individual training or coaching/supervisory support to correctly complete documentation. ii. Case specific audit findings and corrective actions taken will be noted in each record where there was a finding. 5. The identified errors and the related corrective action steps proposed above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (“MICU”) within 90 days to ensure missing documentation has been secured and/or properly noted in record. A. MICU staff will audit records to verify that corrective actions have been completed for case specific audit findings. This includes verifying that records contain a note explaining updated information or information gathered due to audit. B. MICU will work with Branch Administrators, Section Administrators, Social Services Assistants (“SSA”) and program personnel to ensure file updates with completion of missing information. C. MICU will verify accuracy of DOC calculations for case specific errors noted in this audit, while supervisors will verify accuracy of DOC calculations on an ongoing basis. 6. As CWS implements this corrective action plan and monitors the results, the action steps proposed in 1 5 may be modified, based on input from CWS Administrators or exploration groups with line staff who complete this documentation. 7. In preparation for future audits, CWS will update the file identification and secure transport process as follows: A. MICU will send a separate email for records request to each neighbor island, identifying only their records, rather than sending a joint, multi-island, records request. B. The records request email sent by MICU will include a submittal deadline that will accommodate extra time for secured travel of records between islands to ensure all records arrive on time. C. MICU and Branch will review records submitted, ensuring that all records are available to the auditors for review. Completion Date: On going Responding Official(s): Kisha C. Raby, Social Services Division Program Development Administrator; Tonia Mahi, Social Services Division Assistant Child Welfare Services Branch Administrator
View Audit 350226 Questioned Costs: $1
Finding Number: 2024 – 002 – Notification prior to disbursement of Title IV funds Grantor: Department of Education Program Name: Student Financial Assistance Cluster Award Name: Federal Pell Grant Program Award Numbers: not applicable Assistance Listing Titles: Federal Pell Grant Program Assistance ...
Finding Number: 2024 – 002 – Notification prior to disbursement of Title IV funds Grantor: Department of Education Program Name: Student Financial Assistance Cluster Award Name: Federal Pell Grant Program Award Numbers: not applicable Assistance Listing Titles: Federal Pell Grant Program Assistance Listing Numbers: 84.063 Award Year: Fiscal Year 2024 Passthrough Entity: various Corrective Action Plan: Cornell acknowledges that Title IV financial aid was disbursed before a student received their official aid offer due to a manual processing error. To prevent this issue in the future, Cornell implemented a new Peoplesoft system control called a “user edit message” in August 2024. • The new user edit message prevents Title IV and other financial aid disbursements until the system has generated and sent an official aid offer in August 2024. • The new user edit message is assigned (and cleared, when appropriate) via batch system processes that run prior to daily disbursement processes. • On-demand queries were also developed to monitor performance of the control as well as to proactively identify and address any currently unknown circumstances that may result in similar outcomes. • The new controls were implemented in all currently active aid years and will remain as standard controls in future years. Responsible individual: Kevin J. Jensen, Executive Director, Office of Financial Aid and Student Employment
Finding Reference: 2024-012 - SFA Reporting (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: Jackson State University has established a formalized procedure, effective immediately, to ensure the accurac...
Finding Reference: 2024-012 - SFA Reporting (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: Jackson State University has established a formalized procedure, effective immediately, to ensure the accuracy and compliance of the annual Fiscal Operations Report and Application to Participate (FISAP). As part of this process, a FISAP Review Committee will be created to oversee the review of the FISAP and all supporting documentation at least three weeks before the official submission deadline. The FISAP will be prepared by the Executive Director of Student Financial Aid Services and Scholarships, who will also gather and compile all necessary supporting documentation. This completed report, along with all relevant data, will then be submitted to the FISAP Review Committee for thorough examination. The committee will verify the accuracy of all figures and ensure that the supporting documents meet FISAP compliance requirements. Submission of the FISAP will only proceed once the FISAP Review Committee has reached a consensus confirming the accuracy and completeness of the report. This structured review process will help safeguard against errors, enhance compliance, and ensure that JSU meets all federal reporting standards. Estimated Completion Date: September 1, 2025
Finding Reference: 2024-007 - SFA Eligibility (ASU) Responsible Official: Juanita Edwards, Director of Financial Aid Corrective Action Planned: ASU disburses aid to students’ accounts once the student has completed registration. The student was enrolled and eligible for the Pell grant. The student h...
Finding Reference: 2024-007 - SFA Eligibility (ASU) Responsible Official: Juanita Edwards, Director of Financial Aid Corrective Action Planned: ASU disburses aid to students’ accounts once the student has completed registration. The student was enrolled and eligible for the Pell grant. The student had not completed registration, so Pell was not disbursed. Moving forward ASU will review all student accounts to ensure students have completed the registration process. If they have not completed registration timely, they will be notified. Once notified and registration is complete, Title IV funds will be disbursed to the students’ accounts. Checks and balances have been reviewed and implemented to ensure the process is completed timely. Estimated Completion Date: June 30, 2025
View Audit 350191 Questioned Costs: $1
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