Corrective Action Plans

Finding 547313 (2024-002)

Significant Deficiency 2024

CA

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

Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: The University has added an additional audit report to be run prior to submis...

Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: The University has added an additional audit report to be run prior to submission of enrollment reports to Clearinghouse and NSLDS. The report will audit for a change in the reported program begin date between reports when the reported program has not changed. The report inaccurate program begin dates calculated by our Student Information System as a result of a code update sent out by the vendor. Names of the contact persons responsible for corrective action: Shawnn Palmer, Director of Academic Technology and Reporting Planned completion date for corrective action plan: As of March 19, 2025, the student record in the finding has already been corrected. The additional audit report is in draft and will be validated prior to the April reporting.

View Audit 351603

Finding 547305 (2024-001)

Significant Deficiency 2024

California Baptist University

CA

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

Recommendation: We recommend that the University improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Action taken in response to finding: Counselors have completed an intensive R2T4 NASFAA training late April – May 2024. The misunderstanding of the 45-...

Recommendation: We recommend that the University improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Action taken in response to finding: Counselors have completed an intensive R2T4 NASFAA training late April – May 2024. The misunderstanding of the 45-day rule of one of the counselors has been addressed and corrected. Names of the contact persons responsible for corrective action: Joshua Morey, Senior Director of Financial Aid Planned completion date for corrective action plan: As of March 19, 2025, changes and training have already been implemented.

View Audit 351603 Questioned Costs: $1

Finding 547270 (2024-009)

Significant Deficiency 2024

Johnson C. Smith University

NC

Student Financial Aid Internal Control / Segregation of Duties Questioned Costs

Corrective Action Plan: The Student Support Services program experienced changes in program personnel. This change led to a loss of institutional knowledge, interrupted policy and process enforcement. In many instances documentation wasn’t available due to the transition of key program personnel. Du...

Corrective Action Plan: The Student Support Services program experienced changes in program personnel. This change led to a loss of institutional knowledge, interrupted policy and process enforcement. In many instances documentation wasn’t available due to the transition of key program personnel. During the transition for Student Support Service, we encountered difficulty locating explicit documentation for students who were awarded Grant Aid outside of first- or second-year classification. Section 3518(a) of the CARES Act granted the Department authority to “modify the required and allowable uses of funds” for certain programs authorized by the Higher Education Act of 1965, which included TRIO programs. The flexible extension remained in effect until September 30, 2024. Upward Bound requested a flexibility extension under the CARES Act. Due to a delayed response to the request, the extension request was re-sent for verification. Once received, UB was advised that the Department was no longer accepting new requests. As a result, stipends were processed before receiving the final response. During the Spring of 2024 the University began work to enhance its internal controls, policies and procedures to ensure the appropriate documentation was properly maintained. While there was improvement across all TRIO programs, the issues were not fully remediated by June 30, 2024. The University is committed to ensuring compliance with all federal, institutional, and program regulations. The University continues to enhance its internal controls, policies and procedures to ensure the appropriate documentation to support is maintained. Both the Student Support Services and Upward Bound programs are committed to implementing continuous monitoring of program records to ensure compliance with federal, institutional, and program requirements. The TRIO-SSS program has implemented an online Grant Aid application process for all participants who are eligible for aid; which requires submission of demographic information and a need for support statement. With the expiration of exceptions allowed under the CARES Act, all TRIO programs have converted back to distributing stipends in accordance with current federal regulations. Each program will monitor their respective distributions for accuracy and program compliance. Supporting documentation of statutory and regulatory requirements will be retained in the Policy and Procedures manuals. Anticipated Completion Date: June 30, 2025

View Audit 351580 Questioned Costs: $1

Finding 547261 (2024-007)

Significant Deficiency 2024

Johnson C. Smith University

NC

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

Corrective Action Plan: We acknowledge the accuracy of this finding, such that one student’s required return of funds was identified as having been improperly calculated during the R2T4 calculation. The order in which the funds were reduced and returned to the Department was incorrect. Lack of clari...

Corrective Action Plan: We acknowledge the accuracy of this finding, such that one student’s required return of funds was identified as having been improperly calculated during the R2T4 calculation. The order in which the funds were reduced and returned to the Department was incorrect. Lack of clarity about the enrollment level and activity of the student during the term caused the miscalculated award amounts. A lack of system driven calculation and insufficient knowledge of the proper order of funds (and required student authorization of post-withdrawal disbursement) were also contributing factors that resulted in this finding. The University underwent a re-organization the resulted in the creation of a new division, Strategic Enrollment and Retention Management (“SERM”), effective February 2025. The recent organizational restructuring that placed the Registrar’s Office and the Office of Financial Aid under the new division of Strategic Enrollment and Retention Management is a strategic move to enhance the synchronization of essential data between these departments. This alignment is crucial for accurately determining withdrawal dates and understanding the academic calendar, which are essential components of the R2T4 calculation process. Enhanced inter-departmental communication facilitated by this structure will ensure more accurate and timely data sharing, essential for meeting compliance requirements. The ongoing support from FAS in setting up and optimizing Ellucian Colleague for our specific needs will significantly strengthen our capacity to meet and exceed compliance standards, thus preventing future occurrences of similar issues. Starting June 2025, the Financial Aid Office will engage with FSA Partners and utilize NASFAA study materials to conduct comprehensive training for staff responsible for R2T4 calculations. Continuous education will be emphasized to keep staff updated on regulatory changes and best practices. We will utilize the capabilities of Ellucian Colleague to automate R2T4 calculations. This system will be set up to require authorization for post-withdrawal disbursements and ensure that award reductions are calculated in the correct order. We will introduce a secondary review process for all R2T4 calculations, where a seasoned financial aid counselor will verify the accuracy of the initial calculation and authorization documentation. We will standardize the process for documenting the authorization of post-withdrawal disbursements. Develop a standard communication template within Ellucian Colleague that includes explicit requests for student or parent authorization, ensuring compliance with federal regulations. Anticipated Completion Date: September 30, 2025

View Audit 351580

Finding 547259 (2024-006)

Significant Deficiency 2024

Johnson C. Smith University

NC

Student Financial Aid Eligibility Reporting

Corrective Action Plan: A lack of systematic communication between the Registrar’s Office and the Office of Financial Aid, coupled with an absence of an established process flow or calendar to guide quality assurance activities, led to these discrepancies. The University understands that accurate re...

Corrective Action Plan: A lack of systematic communication between the Registrar’s Office and the Office of Financial Aid, coupled with an absence of an established process flow or calendar to guide quality assurance activities, led to these discrepancies. The University understands that accurate reporting of student enrollment status is crucial for managing student eligibility for federal financial aid, including loans and grants; however, in these cases, there were several discrepancies. The University underwent a re-organization the resulted in the creation of a new division, Strategic Enrollment and Retention Management (“SERM”), effective February 2025. SERM aims to address the root causes of this finding by fostering enhanced synergy and communication between the Registrar’s Office and the Office of Financial Aid. This structural change aligns both departments under the governance of the Senior Vice President, ensuring cohesive and compliant operational practices. The alignment will facilitate a unified approach to meet federal reporting requirements more effectively and efficiently, thereby enhancing our administrative capability and compliance with critical federal requirements. This proactive governance restructuring is expected to significantly improve our process accuracy and compliance integrity, safeguarding our students' financial interests and maintaining our standing with federal financial aid programs. In addition, the University will establish audit and verification processes that involve conducting an exhaustive audit of current enrollment reporting processes in collaboration with Financial Aid Services (FAS) to identify and amend discrepancies. We will implement comprehensive, quarterly training for all staff involved in enrollment reporting starting August 2025 to ensure adherence to federal regulations. The Registrar’s Office will establish bi-weekly reporting schedules to the National Student Clearinghouse (NSC), including during summer terms, to ensure timely updates in NSLDS. There will also be regular review sessions to evaluate the effectiveness of the new reporting protocols and make necessary adjustments. Anticipated Completion Date: August 31, 2025

View Audit 351580

Finding 547255 (2024-005)

Significant Deficiency 2024

Johnson C. Smith University

NC

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

Corrective Action Plan: The University acknowledges shortcomings in our institutional processes for managing and communicating the details of Tier One and Tier Two financial arrangements. This has been due to a combination of factors, including outdated website management practices, a lack of clear ...

Corrective Action Plan: The University acknowledges shortcomings in our institutional processes for managing and communicating the details of Tier One and Tier Two financial arrangements. This has been due to a combination of factors, including outdated website management practices, a lack of clear guidelines on compliance responsibilities for web content, and insufficient inter-departmental communication regarding changes in federal regulations and their implications for our disclosure practices. The University is establishing a continuous feedback loop between Financial Aid, the Business Office, and University Communications and Marketing departments to ensure that our contractual disclosures are not only compliant but also clear and accessible to our stakeholders. Enhanced communication and collaboration across these departments are pivotal for maintaining ongoing compliance and ensuring that all disclosures are managed efficiently and transparently. This proactive approach is aimed at fostering a culture of compliance and transparency throughout the University. The University will improve the accessibility and visibility of contractual disclosures on its website to ensure compliance with federal requirements. The updated URLs will be provided to the Department of Education for publication of the contract in a centralized, accessible database. In addition, in partnership with Financial Aid Services (FAS), the University will conduct comprehensive interdepartmental training sessions by August 2025 for all relevant staff, emphasizing the critical nature of compliance with federal disclosure requirements. Anticipated Completion Date: August 31, 2025

View Audit 351580

Finding 547254 (2024-004)

Significant Deficiency 2024

Johnson C. Smith University

NC

Internal Control / Segregation of Duties Questioned Costs Student Financial Aid

Corrective Action Plan: The University relied on third-party technology to notify students of their disbursements without monitoring if their process was being executed. The failure stemmed from inadequate oversight of the notification process, leading to non-compliance with federal requirements for...

Corrective Action Plan: The University relied on third-party technology to notify students of their disbursements without monitoring if their process was being executed. The failure stemmed from inadequate oversight of the notification process, leading to non-compliance with federal requirements for the timely and accurate notification of loan disbursements. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. In addition, as part of the University’s transition of its ERP system from Jenzabar to Colleague, Financial Aid will be transition to Ellucian Colleague for financial aid management. University officials are committed to rectifying this deficiency through significant enhancements to our notification processes and technological infrastructure. The systematic integration of notification with the actual disbursement function via Ellucian Colleague represents a robust solution to ensure compliance. By handling this process internally, we ensure greater control, reliability, and compliance with federal regulations. Regular audits of the disbursement and notification process will be implemented to guarantee that our procedures remain in alignment with federal requirements and best practices. This proactive approach ensures that all loan disbursements are properly managed and communicated, safeguarding both our students' financial interests and the university's compliance status. The university has already begun to amend procedures to ensure that all loan disbursements are accompanied by timely and accurate notifications. The Office of Financial Aid will maintain detailed records showing compliance with these notifications. The integration of Ellucian Colleague will automate the notification process. This system ensures that notifications are sent immediately upon disbursement processing, using various modalities such as email, text messages, or direct updates to the student portal. We will enhance our enhance record-keeping through the utilization of Ellucian Colleague by logging all communications sent, ensuring that there is traceable evidence of compliance. This system integration addresses previous dependencies on third-party technologies and brings control of this crucial compliance aspect in-house. Anticipated Completion Date: September 30, 2025

View Audit 351580

Finding 547250 (2024-003)

Significant Deficiency 2024

Johnson C. Smith University

NC

Internal Control / Segregation of Duties Questioned Costs Student Financial Aid

Corrective Action Plan: The verification for one student was improperly conducted, leading to financial aid awards and disbursements based on unverified or incorrectly verified financial data, specifically regarding untaxed IRA distributions and pensions. The verification failure was due to an overs...

Corrective Action Plan: The verification for one student was improperly conducted, leading to financial aid awards and disbursements based on unverified or incorrectly verified financial data, specifically regarding untaxed IRA distributions and pensions. The verification failure was due to an oversight by the aid administrator who incorrectly verified the untaxed IRA distribution and pension as zero, despite contradictory evidence or a lack of supporting documentation. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. Resulting from the work of FAS, the verification policies will be thoroughly reviewed, and revised, to ensure comprehensive coverage as mandated by federal regulations. The University will also establish a robust quality control system to regularly review verification practices and compliance, ensuring adherence to updated policies. We will update and maintain a verification checklist that includes all data elements required for verification. This checklist will be used in all verifications, with a secondary review and sign-off by another trained administrator to ensure accuracy and completeness. In addition, we will bolster training for all financial aid staff, utilizing resources from FAS and the National Association of Student Financial Aid Administrators (NASFAA) to deepen understanding and expertise in verification processes. Anticipated Completion Date: September 30, 2025

View Audit 351580

Finding 547248 (2024-002)

Significant Deficiency 2024

Johnson C. Smith University

NC

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

Corrective Action Plan: The inaccuracies stemmed from insufficient workflow integration among the Office of Financial Aid and the Registrar’ Office. A critical lack of scheduled checks failed to align submission or processing dates. Furthermore, technical issues between Jenzabar and PowerFAIDS syste...

Corrective Action Plan: The inaccuracies stemmed from insufficient workflow integration among the Office of Financial Aid and the Registrar’ Office. A critical lack of scheduled checks failed to align submission or processing dates. Furthermore, technical issues between Jenzabar and PowerFAIDS systems contributed to erroneous COA budgets. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. In addition, as part of the University’s transition of its ERP system from Jenzabar to Colleague, Financial Aid will be transition from the use of PowerFaids to Ellucian Colleague for financial aid management. Resulting from the work of FAS, the University will institute a systematic monthly reconciliation process to ensure consistency across all systems (COD, PowerFAIDS, Jenzabar and Colleague). This includes matching COA and disbursement records to ensure accuracy. To optimize workflow, we will establish a comprehensive calendar of disbursement and reporting deadlines, with routine internal audits every 30 days, starting April 2025. This measure will enforce accountability and timeliness in reporting. We will enhance integration between financial systems (Jenzabar and PowerFAIDS) to prevent data mismatches and streamline the reporting process. In addition, we will leverage our partnership with FAS to conduct regular training sessions for staff across the Financial Aid, Registrar, and Finance Offices to ensure everyone is aware of compliance requirements and system functionalities. These training sessions will start May 2025. Anticipated Completion Date: September 30, 2025

View Audit 351580

Finding 547245 (2024-001)

Significant Deficiency 2024

Johnson C. Smith University

NC

Questioned Costs Student Financial Aid Subrecipient Monitoring

Corrective Action Plan: The University did not appropriately review eligibility documentation resulting in over awards. The error arose due to the manual processing of student loans by a single financial counselor without adequate checks, leading to non-compliance with specific fund restrictions rel...

Corrective Action Plan: The University did not appropriately review eligibility documentation resulting in over awards. The error arose due to the manual processing of student loans by a single financial counselor without adequate checks, leading to non-compliance with specific fund restrictions related to the student’s year in school and dependency status. A significant contributing factor was the absence of structured, periodic quality assurance reviews. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. In addition, as part of the University’s transition of its ERP system from Jenzabar to Colleague, Financial Aid will transition from the use of PowerFaids to Ellucian Colleague for financial aid management, which was driven by the need for more robust, systematic controls that can accurately adjust and calculate Cost of Attendance (COA) on a per-student basis. This system change is expected to automate many of the processes that were previously prone to human error, ensuring compliance with regulatory requirements. The University’s Financial Aid counselors will continue to monitor students' credit hours and make necessary adjustments to aid awards, thereby maintaining compliance and addressing any discrepancies proactively. This plan reflects our commitment to upholding the highest standards of financial aid management and ensuring that our processes are transparent, compliant, and responsive to the needs of our students. The University will integrate automated processes in our financial aid packaging to reduce human error. The adoption of the Ellucian Colleague system by JCSU will allow for automatic enforcement of packaging and transmittal rules, tailored to specific funds. Additionally, we will utilize exception reports from Ellucian Colleague to identify and correct discrepancies in real-time. We will establish a routine monitoring system to regularly check the accuracy of financial aid awards against eligibility criteria. Anticipated Completion Date: September 30, 2025

View Audit 351580 Questioned Costs: $1

Finding 547232 (2024-001)

Significant Deficiency 2024

The University of Charleston, INC

WV

Reporting Student Financial Aid

The University recognizes the untimely staff turnover and the impact it has had on University compliance. University leadership has taken steps to ensure immediate and future compliance with the regulations referenced in this finding. The following corrective action plan has been implemented to prev...

The University recognizes the untimely staff turnover and the impact it has had on University compliance. University leadership has taken steps to ensure immediate and future compliance with the regulations referenced in this finding. The following corrective action plan has been implemented to prevent delays in future reporting. An experienced Institutional Researcher (IR) has been hired for the University, with over 20 years of student enrollment data management and reporting to the National Student Clearinghouse (Clearinghouse). The schedule for reporting student enrollment has been modified to reflect reporting within 30-to-45-day intervals. Reporting at this interval will ensure compliance with the 60-day requirement. Email notifications of enrollment reports due, enrollment reports submitted, correction reports, and report delinquencies from the Clearinghouse are now sent to the IR, the Registrar, and the Provost’s Office. The Provost and the IR meet at least weekly regarding compliance and ongoing reporting for the University.

View Audit 351564

Finding 547169 (2024-001)

Material Weakness 2024

Washington and Lee University

VA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action Plan to Finding 2024‐001: Contact person for corrective action: Melissa Neal, Registrar Correction Action Plan: The University plans to implement the following: During the 2024‐2025 academic year, the Registrar Office will implement the following mechanisms to ensure that all statu...

Corrective Action Plan to Finding 2024‐001: Contact person for corrective action: Melissa Neal, Registrar Correction Action Plan: The University plans to implement the following: During the 2024‐2025 academic year, the Registrar Office will implement the following mechanisms to ensure that all status change records are reported to NLSDS accurately.  Reinforce training of individuals in the compliance and control ownership roles to ensure controls are operating as designed.  Ensure that individuals in compliance and control ownership roles within the Registrar’s office validated that enrollment files submitted were processed in the correct sequence.

View Audit 351524

Finding 547165 (2024-006)

Significant Deficiency 2024

Georgetown College

KY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Perkins Loan Program, 84.038 Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work Study Program, 84.033 Criteria: The College is required to comply with 34 CFR Section 674.19, 34 CFR 675....

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Perkins Loan Program, 84.038 Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work Study Program, 84.033 Criteria: The College is required to comply with 34 CFR Section 674.19, 34 CFR 675.19 and 34 CFR 676.19. Condition: During our testing of the Fiscal Operations Report and Application to Participate (FISAP), we noted that Part II (Application), Section E, Line 22: total tuition and fees for the award year July 1, 2023 to June 30, 2024 did not agree or reconcile to the statement of activities. Cause: The College did not have controls in place to ensure FISAP reporting was accurate. Effect: The College did not follow federal regulations regarding FISAP reporting accuracy. The provisions of 34 CFR Section 674.19, 34 CFR 675.19 and 34 CFR 676.19 were not followed and thus the total tuition and fees for the award year July 1, 2023 to June 30, 2024 reported on the FISAP were greater than the tuition and fees on the statement of activities by $368,034. Questioned Costs: There are no questioned costs associated with this finding. Recommendation: We recommend that the College implement a control to ensure FISAP reporting is accurate. Corrective Actions Taken or Planned: The College concurs with the finding. A system of controls will be implemented to ensure accurate data is reported on all required reporting. Individual Responsible for Corrective Action: Katie Palmer, Director of Financial Planning Expected Completion Date: August 2025

View Audit 351511

Finding 547163 (2024-004)

Significant Deficiency 2024

Georgetown College

KY

Student Financial Aid Eligibility Reporting

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Loan Program, 84.268 Criteria: The College is required to comply with 34 CFR Section 685.304(a)(2). Condition: During our testing of eligibility, we selected 40 samples and noted three instances wher...

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Loan Program, 84.268 Criteria: The College is required to comply with 34 CFR Section 685.304(a)(2). Condition: During our testing of eligibility, we selected 40 samples and noted three instances where the loan disbursement date on the student's leger did not agree to the disbursement date on Common Origination and Disbursement (COD). Cause: The College did not have controls in place to properly review COD disbursement dates to verify all students had proper reporting to COD. Effect: The College did not follow federal regulations regarding reporting to COD. The provisions of 34 CFR Section 685.301(a)(2) were not followed and thus three students loans were improperly reported to COD. Questioned Costs: There are no questioned costs associated with this finding. Recommendation: We recommend that the College review all COD disbursements and perform monthly COD reconciliations by student to verify the disbursement date and amount matches the student ledger. Corrective Action Taken or Planned: The College concurs with the finding. Controls have already been implemented to ensure accurate and timely reporting to COD. Individual Responsible for Corrective Action: Katie Palmer, Director of Financial Planning Expected Completion Date: November 2024

View Audit 351511

Finding 547162 (2024-003)

Significant Deficiency 2024

Georgetown College

KY

Questioned Costs Student Financial Aid Eligibility

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Loan Program, 84.268 Criteria: The College is required to comply with 34 CFR Section 685.304(a). Condition: During our testing of eligibility, we selected 40 samples and noted two instances where a s...

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Loan Program, 84.268 Criteria: The College is required to comply with 34 CFR Section 685.304(a). Condition: During our testing of eligibility, we selected 40 samples and noted two instances where a student was disbursed a direct loan prior to entrance counseling being completed. Cause: The College did not have controls in place to ensure entrance counseling was completed prior to a loan disbursement. Effect: The College did not follow federal regulations regarding loan disbursements. The provisions of 34 CFR Section 385.304(a) were not followed and thus two students were improperly disbursed a direct loan. Questioned Costs: There are a total of $9,250 of questioned costs associated with this finding. $5,192j related to subsidized loans and $4,058 related to unsubsidized loans. Recommendation: We recommend that the College implement a control to ensure loans are not disbursed to students until entrance counseling has been completed by the student. Corrective Action Taken or Planned: The College agrees with the finding. Controls have already been implemented to ensure that compliance with all federal and state requirements are met before aid is disbursed. Individual Responsible for Corrective Action: Katie Palmer, Director of Financial Planning Expected Completion Date: November 2024

View Audit 351511 Questioned Costs: $1

Finding 547161 (2024-002)

Significant Deficiency 2024

Georgetown College

KY

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

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Loan Program, 84.268 Criteria: The College is required to comply with 34 CFR Section 685.309(b ). Condition: During our testing of eligibility, official withdraws, and student status changes for grad...

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Loan Program, 84.268 Criteria: The College is required to comply with 34 CFR Section 685.309(b ). Condition: During our testing of eligibility, official withdraws, and student status changes for graduates, we selected 40, one, and 21 samples, respectively. We noted three instances in eligibility testing, one instance in official withdraws, and one instance in student status change for graduates where a student's status changes were either not reported timely or accurately to the National Student Loan Database System (NSLDS). Cause: The College did not have controls in place to ensure student's classification were being properly reported to the NSLDS. Effect: Student status changes were not reported within the required timeframe under federal regulations. The provisions of 34 CFR Section 685.309(b) were not followed and thus two students were not reported and subsequently not placed into loan repayment status in a timely manner. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the College implement a control to ensure data is being reviewed for accuracy by the appropriate personnel before roster files are submitted to NSLDS. In addition, we recommend that the College submit roster files on a regular basis. Corrective Actions Taken or Planned: The College concurs with the finding. The Registrar's Office will implement a system of reviews and controls that ensure timely and accurate reporting of student status changes to the National Student Loan System (NSLDS). Individual Responsible for Correction Action: Katie Palmer, Director of Financial Planning Expected Completion Date: August 2025

View Audit 351511

Finding 547091 (2024-003)

Significant Deficiency 2024

Alverno College

WI

Internal Control / Segregation of Duties Questioned Costs Special Tests & Provisions

Condition The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NS...

Condition The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that the Department of Education (ED) considers high risk. Corrective Action Plan Corrective Action Planned: The Registrar will pull a sample of students from the Clearinghouse enrollment update or change submissions to ensure NSLDS has been updated to reflect changes within the 60-day window. Name(s) of Contact Person(s) Responsible for Corrective Action: Marlene Neises, Executive Director for Institutional Effectiveness and Sponsored Programs; and David Brzeczkowski, Controller. Anticipated Completion Date: This will be completed by June 30, 2025.

View Audit 351446

Finding 547085 (2024-002)

Significant Deficiency 2024

Alverno College

WI

Internal Control / Segregation of Duties Questioned Costs Student Financial Aid

Condition The College’s internal controls over compliance requirements over the return of Title IV funds (R2T4) were not operating effectively in 2024 as the College did not comply with the federal requirements as it relates to issuing a credit to a student. Corrective Action Plan Corrective Action ...

Condition The College’s internal controls over compliance requirements over the return of Title IV funds (R2T4) were not operating effectively in 2024 as the College did not comply with the federal requirements as it relates to issuing a credit to a student. Corrective Action Plan Corrective Action Planned: The College will review processes and data collection related to students’ withdrawal or leave of absence. The result of this review will be a full operational and procedural detail of responsibilities, roles, timelines and documentation associated with the accurate processing of all withdrawals. To include Student Records, Student Accounts, Financial Aid and Return to Title IV. Name(s) of Contact Person(s) Responsible for Corrective Action: Naomi Coe, Financial Aid Director; Mariana Sanabria, VP for Enrollment Services; Marlene Neises, Executive Director for Institutional Effectiveness and Sponsored Programs; David Brzeczkowski, Controller; and Amanda Hodgson, CIO. Anticipated Completion Date: A preliminary meeting is scheduled for March 31, 2025 to discuss the implementation of the processes and responsibilities pertaining to a student withdraw and leave of absence. This meeting will provide an outline of the internal controls and processes to be implemented by July 31, 2025.

View Audit 351446 Questioned Costs: $1

Finding 547053 (2024-002)

Significant Deficiency 2024

Concordia University Texas

TX

Student Financial Aid Subrecipient Monitoring Questioned Costs

An action plan has been made in conjunction with IT to ensure more timely and accurate notifications of student schedule changes/withdrawals and processing of required adjustments to aid. We will be implementing a more automatic process that will assist with the work flow and efficiency of these pro...

An action plan has been made in conjunction with IT to ensure more timely and accurate notifications of student schedule changes/withdrawals and processing of required adjustments to aid. We will be implementing a more automatic process that will assist with the work flow and efficiency of these processes.

View Audit 351424

Finding 547052 (2024-001)

Significant Deficiency 2024

Concordia University Texas

TX

Questioned Costs Student Financial Aid Subrecipient Monitoring

The University will strengthen internal controls and monitoring processes to ensure compliance with Title IV credit balance regulations. Specific corrective actions include: 1. Implementing a weekly audit of credit balances within the student financial system to identify and initiate refund process ...

The University will strengthen internal controls and monitoring processes to ensure compliance with Title IV credit balance regulations. Specific corrective actions include: 1. Implementing a weekly audit of credit balances within the student financial system to identify and initiate refund process when a Title IV credit balance exceeds the allowable time frame. 2. Providing and accessing additional training to financial aid and student accounts personnel on Title IV regulations regarding credit balances and timely refunds. 3. Establishing a formalized procedure for escalating unresolved balances to senior financial administrators for immediate corrective action.

View Audit 351424 Questioned Costs: $1

Finding 547039 (2024-001)

Material Weakness 2024

Regent University

VA

Student Financial Aid Reporting Material Weakness § 200.303 § 200.516

Regent University agrees with this finding. The University will engage with the National Student Clearinghouse audit support office and will establish a working group with appropriate Regent stakeholders to review suggested changes made by the NSC to reporting methods, time buffers between reports, ...

Regent University agrees with this finding. The University will engage with the National Student Clearinghouse audit support office and will establish a working group with appropriate Regent stakeholders to review suggested changes made by the NSC to reporting methods, time buffers between reports, reporting frequency, and other “upstream” preventative measures that may be taken to prevent file backlogs. Internally, the University will establish formalized communication protocols between departments to be enacted in the case of an NSC enrollment reporting file delay that could result in noncompliance with enrollment reporting requirements. Regent University will establish a reporting process directly between the University and NSLDS to be used in the event of an NSC backlog that cannot be mitigated within the compliance window. Regent University will implement the first and second parts of this plan by June 30, 2025 and the final component (NSLDS direct file reporting process) by September 30, 2025. Name of responsible parties: Elizabeth Bayless (University Registrar) & Tameka Lyons (Associate Registrar)

View Audit 351409

Finding 547012 (2024-002)

None 2024

Caribbean University, Inc.

PR

Student Financial Aid

The University reviewed its processes and internal controls and established training for the Register, Financial Aid Office and the Offices of Academic Deans to ensure that this report is submitted within the regularly timeframe. The results of these efforts will be effective during the 2025-2026 fi...

The University reviewed its processes and internal controls and established training for the Register, Financial Aid Office and the Offices of Academic Deans to ensure that this report is submitted within the regularly timeframe. The results of these efforts will be effective during the 2025-2026 fiscal year.

View Audit 351393

Finding 547011 (2024-001)

None 2024

Caribbean University, Inc.

PR

Student Financial Aid Matching / Level of Effort / Earmarking

The University experimented numerous personal changes in the Register and Financial Aid Office, resulting complicated the continuity of established policies and processes. However, the University reviewed its processes and internal controls and established training for the Register and Financial Aid...

The University experimented numerous personal changes in the Register and Financial Aid Office, resulting complicated the continuity of established policies and processes. However, the University reviewed its processes and internal controls and established training for the Register and Financial Aid Office to ensure this report is submitted within the regularly timeframe. The results of these efforts will be effective during the 2025-2026 fiscal year

View Audit 351393

Finding 546965 (2024-003)

Significant Deficiency 2024

Avila University

MO

Student Financial Aid Questioned Costs Special Tests & Provisions

Enrollment information was not submitted accurately or within the required timeframe by the University. Personnel Responsible for Corrective Action: Margaret Herron, Registrar. Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2025. Corrective Action Plan: Managemen...

Enrollment information was not submitted accurately or within the required timeframe by the University. Personnel Responsible for Corrective Action: Margaret Herron, Registrar. Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2025. Corrective Action Plan: Management has provided training and the financial aid department will make regular updates to NSLDS on a monthly basis to ensure student information is reported accurately and timely.

View Audit 351349

Finding 546957 (2024-001)

None 2024

Santa Fe Community College

NM

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Santa Fe Community College respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the n...

Santa Fe Community College respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS III – Federal Award Findings 2024-001 – Compliance Requirements Over Reporting-Fiscal Operations Report and Application to Participate (FISAP) (Other Non-Compliance) Responsible Party: Nick Telles – Vice President of Finance and Jacob Pacheco – Chief Financial Officer and Financial Aid Director. Corrective Action Plan: Management concurs with this finding. Preliminary FISAP was entered into the Campus Based System (CBS) in order to perform built-in validation checks in CBA. The erroneous data was based on a Banner-generated FISAP report dated 8/21/2024. The final FISAP data was entered using a Banner reported generated 09/26/2024 but the field referenced within the finding were not entered when finalizing the data. Institutions are allowed to make corrections to the FISAP until December 15th each calendar year. Once identified, the corrections were submitted on 10/24/2024. Anticipated Completion Date: June 30, 2025 If there are any questions regarding this plan, please call Nick Telles at 505-428-1161 or email at nick.telles@sfcc.edu or Jacob Pacheco at 505-428-1814 or email at jacob.pacheco@sfcc.edu.

View Audit 351337

Corrective Action Plans

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