Corrective Action Plans

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Condition: The College did not have appropriate segregation of duties in place to ensure the reporting to COD is being reviewed by an individual separate from the process of preparing the reconciliations. Planned Corrective Action: The College will modify its process and update its documented proced...
Condition: The College did not have appropriate segregation of duties in place to ensure the reporting to COD is being reviewed by an individual separate from the process of preparing the reconciliations. Planned Corrective Action: The College will modify its process and update its documented procedures to include an appropriate review of the reconciliation by an individual separate from the process of preparing the reconciliations. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: June 30, 2026
Condition: The College did not provide notifications to certain students related to direct loan disbursements. Planned Corrective Action: The Director of Financial Aid will work with our information technology department to ensure the criteria used for triggering the notification emails is correct a...
Condition: The College did not provide notifications to certain students related to direct loan disbursements. Planned Corrective Action: The Director of Financial Aid will work with our information technology department to ensure the criteria used for triggering the notification emails is correct and capturing all the necessary students. Additionally, an exception report will be created to identify students who have not been sent the notification email for the financial aid department to review and then send the appropriate notification. The department procedures will be updated to reflect these changes in process. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: March 31, 2026
Condition: Out of 60 students tested for return to Title IV, we identified 4 students whose calculations were performed outside of the required time frame. Planned Corrective Action: The College will work with its Director of Financial Aid to ensure the semester end procedures include steps to ident...
Condition: Out of 60 students tested for return to Title IV, we identified 4 students whose calculations were performed outside of the required time frame. Planned Corrective Action: The College will work with its Director of Financial Aid to ensure the semester end procedures include steps to identify those students who unofficially withdrew. Once the students are identified, individuals with appropriate skills and knowledge will be able to determine if a return of Title IV calculation is necessary and appropriately return any funds, as necessary. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: March 31, 2026
The officials responsible for Student Accounts acknowledge that certain student financial aid refunds were processed outside the 14-day federal deadline, primarily due to insufficient Title IV training during the initial transfer of responsibilities to Student Accounts. While a standard operating pr...
The officials responsible for Student Accounts acknowledge that certain student financial aid refunds were processed outside the 14-day federal deadline, primarily due to insufficient Title IV training during the initial transfer of responsibilities to Student Accounts. While a standard operating procedures (SOP) exists within the current refunds training, it is limited, focusing primarily on the reports and some of federal requirements but does not provide sufficient detail on regulations, reviews, approvals, and timelines. Student Accounts has already taken steps to address and correct the misinformation, but additional improvements are still needed. The SOP for refunds is currently in progress to fully incorporate all necessary items to ensure better and clearer training guidelines. Mandatory Title IV refund training will be provided to all Refund Representatives and included in onboarding for new hire. We shall set established expectations set for all individuals involved in the process, including their delegates, to ensure accountability and consistent application of procedures. Ongoing collaboration with Financial Aid will ensure procedures are consistently applied, questions are addressed, and staff remain current with requirements. These actions are expected to ensure compliance with the 14-day federal requirement, strengthen staff competency, and support continuous improvement in refund processing. Person(s) Responsible: Student Accounts Manager (training), Associate Vice President & Controller Targeted Correction Date: June 30, 2026
At the end of the 2023–24 award year, responsibility for generating Return of Title IV (R2T4) withdrawal lists transitioned from the Business Office to the Financial Aid Office. The Financial Aid Office began producing both official withdrawal and unofficial (non-passing grade) reports through Elluc...
At the end of the 2023–24 award year, responsibility for generating Return of Title IV (R2T4) withdrawal lists transitioned from the Business Office to the Financial Aid Office. The Financial Aid Office began producing both official withdrawal and unofficial (non-passing grade) reports through Ellucian Banner. Because the two reports produced nearly identical student listings, it was assumed that the Banner-generated unofficial withdrawal report was effectively identifying all students who had received non-passing grades.During an internal audit conducted at the end of the Spring 2025 semester, the University identified one student who had failed all courses and was not included on either of the R2T4 lists. Upon further review, the issue was traced to a reporting limitation within Banner that excluded some students with all failing grades from the population used for R2T4 review. To resolve this, the Financial Aid Office coordinated with the Registrar’s Office to obtain a complete list of students who officially withdrew and students with all non-passing grades once final grades were submitted. R2T4 calculations were subsequently performed for applicable students identified in this additional list. Since Spring 2025, the University has institutionalized this revised procedure. The Registrar’s Office now provides the Financial Aid Office with a list of all students with non-passing grades at the end of each semester once grades are submitted. The Financial Aid Office reviews both reports to identify potential unofficial withdrawals and performs R2T4 calculations as required. To strengthen oversight and prevent future omissions during staffing transitions or process changes, the University will: • Document the revised R2T4 identification and review process in the Financial Aid operations manual. • Clearly assign responsibility for report generation, review, and follow-up between the Registrar’s Office and Financial Aid Office. • Implement a quarterly internal cross-check to confirm all required R2T4 reviews are completed. Person(s) Responsible: Associate Director of Financial Aid and Director of Financial Aid. Correction Date: January 31, 2026. This issue is resolved.
The University has made substantial progress toward completing the remaining elements required under the Gramm-Leach-Bliley Act (GLBA) and aligning its program with the FTC Safeguards Rule. Full implementation timelines are primarily constrained by current staffing capacity within ITS/Cybersecurity ...
The University has made substantial progress toward completing the remaining elements required under the Gramm-Leach-Bliley Act (GLBA) and aligning its program with the FTC Safeguards Rule. Full implementation timelines are primarily constrained by current staffing capacity within ITS/Cybersecurity and Legal, as well as certain technical tool limitations (e.g., data discovery and validation). Despite these constraints, notable progress has been achieved across the required FTC Safeguards Program elements as summarized below: • Element 1 – Designate a Qualified Individual: Completed. Qualified individual appointed to implement and supervise the company’s information security program; reporting mechanisms to the Board established. Completion is confirmed based on oversight and execution of subsequent program elements. • Element 2 – Conduct a Risk Assessment: Completed. Initial risk assessment conducted to identify reasonably foreseeable threats; controls and priorities for Elements 3–9 is being guided by this assessment. • Element 3 – Access Controls & Data Classification: 70% complete. Policies finalized; multi- factor authentication (MFA) implemented; initial asset inventory completed. Data owner assignments and detailed access reviews are in progress. • Element 4 – Vulnerability Management: Complete. Latest penetration testing identified no critical findings. • Element 5 – Information Security Policies: Drafted and pending Legal review; Board acceptance scheduled for March 2026. • Element 6 – Third-Party Oversight: 70% complete. Policy and workflow developed; Board acceptance scheduled for March 2026. • Element 7 – Periodic Risk Assessments: 80% complete. Updated risk assessment currently in progress. • Element 8 – Incident Response Plan: 90% complete. Final reporting and approval scheduled for March 2026. • Element 9 – Qualified Individual & Board Reporting: 90% complete. Annual report scheduled for March 2026. • Red Flags Rule (Identity Theft Prevention): 50% complete. Policy drafted, complete comprehensive program, formal procedures and additional trainings still required. Next Steps: Remaining actions will be completed as Legal and Board approvals are obtained and staffing capacity allows. HPU will continue to develop and retain documentation supporting the completion and implementation of each safeguard element, as prescribed by GLBA. Periodic internal assessments of the Information Security Program will be scheduled following full implementation, with consideration given to engaging an independent third party for future reviews. Person(s) Responsible: Information Security Officer; Vice President of Operations and Chief Information Officer. Targeted Correction Date: March 31, 2026.
The College will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.
The College will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.
The College will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.
The College will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.
The College will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.
The College will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.
The College will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.
The College will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.
Annual performance reports will be submitted on time as required by the funding agency. Management has developed a comprehensive listing of all reporting requirements and will utilize this information to ensure all reporting requirements are met.
Annual performance reports will be submitted on time as required by the funding agency. Management has developed a comprehensive listing of all reporting requirements and will utilize this information to ensure all reporting requirements are met.
Management will provide additional resources to the Financial Aid department to include training and assistance and will implement verification procedures to ensure that amounts awarded are accurate.
Management will provide additional resources to the Financial Aid department to include training and assistance and will implement verification procedures to ensure that amounts awarded are accurate.
Finding Number: 2025-002 - Inadequate Internal Control over Return of Title IV Funds Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely return of Title IV funds for all students within the required time period. Planned Correc...
Finding Number: 2025-002 - Inadequate Internal Control over Return of Title IV Funds Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely return of Title IV funds for all students within the required time period. Planned Corrective Action: From University Response: The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures. From last year's CAP: The University has streamlined the process of R2T4 to prevent delays in processing. This enhanced process creates a countdown report to prioritize R2T4 calculation when staff resources as strained. Contact person responsible for corrective action: Roberta Smith Anticipated Completion Date: 06/30/2026
Finding Number: 2025-001 - Inadequate Internal Control over Student Enrollment Reporting Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate enrollment reporting for all students. Planned Corrective Action: The University is implementing...
Finding Number: 2025-001 - Inadequate Internal Control over Student Enrollment Reporting Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate enrollment reporting for all students. Planned Corrective Action: The University is implementing enhanced internal controls to ensure enrollment status changes and degree confirmations are being appropriately submitted and reported. Contact person responsible for corrective action: Roberta Smith/Sarah Lawson Anticipated Completion Date: 06/30/2027
Corrective Action Plan for the Year Ending June 30, 2025 Finding 2025-001: Significant Deficiency – Lack of Documented Controls – Cash Management Program: Student Financial Assistance Cluster Assistance Listing Number: various Federal Agency: U.S. Department of Education Federal Award Identification...
Corrective Action Plan for the Year Ending June 30, 2025 Finding 2025-001: Significant Deficiency – Lack of Documented Controls – Cash Management Program: Student Financial Assistance Cluster Assistance Listing Number: various Federal Agency: U.S. Department of Education Federal Award Identification Number: various Federal Award Year: June 30, 2025 Repeat Finding: 2024-001 Criteria: The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. Condition/Context: For six of eight selected G5/G6 Title IV drawdown transactions, there was no documented internal controls in place over cash management drawdowns. Despite the lack of documented controls over the cash drawdowns, there were no compliance exceptions noted. The sample was not a statistically valid sample. Cause: The College indicated the control of review was more informal/verbal and although had started documenting via email during the year, the documentation was not maintained. Questioned Costs: Not applicable Effect: The College could drawdown an incorrect amount although compensation controls/reconciliations would likely catch the error. Recommendation: The College should document controls in place to ensure cash drawdowns are complete and accurate. This should include a review by someone other than the preparer prior to the drawdown being requested in G5/G6. Action Taken: Management concurs with the finding and has taken the appropriate actions to remediate the significant deficiency. The team has made improvements to become more formal by implementing written communication among all members involved in the process. Each member of their respective roles are communicating through email presenting the step by step process of the review and approval before the drawdown of cash from G5/G6. Name(s) of Contact Person Responsible for Corrective Action: Kevin Brand, Director of Operations and Systems for Financial Aid; Laurie Klizos, Director of Student Accounts; Seong Nevins, Controller. Anticipated Completion Date: June 30, 2026 Signed by Charlie Faas and Jim Brooks
Cash Management - Excess Cash on Hand Auditor Description of Condition and Effect. During our testing of cash management for campus-based aid, we noted one instance out of six drawdowns tested, that the College drew down Federal Work Study funds that were not needed for immediate disbursement, and w...
Cash Management - Excess Cash on Hand Auditor Description of Condition and Effect. During our testing of cash management for campus-based aid, we noted one instance out of six drawdowns tested, that the College drew down Federal Work Study funds that were not needed for immediate disbursement, and was not returned timely. As a result of this condition, the College was not in compliance with the Uniform Guidance cash management principles. Auditor Recommendation. We recommend the College strengthen its cash‑management controls to ensure Title IV drawdowns are limited to immediate disbursement needs, reconciled promptly, and any excess cash is identified and returned within required regulatory timeframes. Corrective Action. The College is enhancing its federal cash management practices by limiting drawdowns for campus‑based programs, including Federal Work‑Study, to immediate disbursement needs. Drawdowns are now based on a documented three‑day cash needs forecast to ensure compliance with federal requirements. A standardized drawdown checklist requires staff to reconcile all G5 activity to the general ledger and subsidiary ledgers on the same day funds are drawn or disbursed. Any excess cash identified through this process is returned to the Department of Education via G5 within one business day. Monthly management reviews monitor drawdown timing, cash balances, and reconciliation trends to ensure continued compliance. Staff have been retrained on updated cash management procedures, and quarterly monitoring reports are produced and retained as evidence of ongoing compliance with federal cash management standards. Responsible Person. Jennifer Stimson, Director of Financial Aid with support from Scott Kemmer-Slater, Director of Accounting. Anticipated Completion Date. June 30, 2026
Student Credit Balance Exceeding Fourteen Days Auditor Description of Condition and Effect. During our testing, we identified one instance in which a student’s credit balance remained outstanding beyond the required 14‑day timeframe. As a result of this condition, the College was not in compliance w...
Student Credit Balance Exceeding Fourteen Days Auditor Description of Condition and Effect. During our testing, we identified one instance in which a student’s credit balance remained outstanding beyond the required 14‑day timeframe. As a result of this condition, the College was not in compliance with the Uniform Guidance requirements governing the timely disbursement of student credit balances. Auditor Recommendation. We recommend the College implement procedures to ensure all voided refunds are reviewed and resolved within the fourteen day period to ensure there are no credit balances that are unaddressed. Corrective Action. The College is strengthening its procedures to ensure student credit balances are processed, refunded, or returned within the federally required 14‑day timeframe. When a student requests a stop payment, hold, or void, the student must now email both the Business Office and Financial Aid Office from their official MCC student email account. Requests must include the type of action needed and the reason for it. The Directors of Accounting and Financial Aid, or designated authorized personnel, review and approve each request before any action is taken. The Business Office then issues the stop payment, hold, or void in accordance with internal procedures, while Financial Aid returns funds to the appropriate agency when applicable. For internal staff‑initiated stop or void actions, employees must email the Directors with justification explaining why the request is being initiated by staff rather than the student. Both offices collaborate to determine appropriate action, ensure the disbursement is adjusted, coordinate the timing of any required return of funds, and communicate updates to the student. These procedures ensure all credit balance transactions are processed within the 14‑day limit and are documented consistently to maintain federal compliance. Responsible Person. Scott Kemmer-Slater, Director of Accounting and Jennifer Simson, Director of Financial Aid, jointly. Anticipated Completion Date. June 30, 2026
Cost of Attendance Calculation Inputs Auditor Description of Condition and Effect. During our testing of the College’s cost of attendance (COA) calculations, we identified inconsistencies between the COA component amounts recorded in the system and the amounts documented on the College’s COA calcula...
Cost of Attendance Calculation Inputs Auditor Description of Condition and Effect. During our testing of the College’s cost of attendance (COA) calculations, we identified inconsistencies between the COA component amounts recorded in the system and the amounts documented on the College’s COA calculation sheet. For instance, the College's tuition component was supposed to be based on credit intensity, but instead was being calculated using the student's enrollment status (e.g., full-time, half-time, etc.). Additionally, the College included direct loan fees in every students COA, even if they were not a direct loan receiving student. As a result, COA amounts used in awarding Title IV aid were being understated, preventing some students from potentially receiving additional aid they were entitled to. Auditor Recommendation. We recommend that the College establish and adhere to review procedures to ensure that all inputs used in the COA calculation are accurate, complete, and consistent with approved documentation. Corrective Action. Management is actively enhancing the College’s Cost of Attendance (COA) processes to ensure all inputs—particularly tuition, loan fees, and enrollment‑related components—accurately reflect approved documentation and federal requirements. The Financial Aid Office has reconfigured PowerFAIDS to calculate tuition based on credit intensity rather than enrollment status, and loan fees are now included only for students who actually borrow federal loans. An annual COA governance and approval process is now in place, requiring review and authorization by the Vice President of Finance and Administration before COA figures are built into the system. All COA entries in PowerFAIDS undergo an independent verification against the approved COA worksheet as part of a “build‑to‑proof” procedure. Spot checks are conducted at the start of each term to ensure accuracy across enrollment levels, and all mid‑year changes are documented using a formal change‑control log. Responsible Person. Jennifer Stimson, Director of Financial Aid Anticipated Completion Date. March 31, 2026
Fiscal Operations Report and Application to Participate (FISAP) Reporting Auditor Description of Condition and Effect. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items (information on eligible aid applicants) identified in the com...
Fiscal Operations Report and Application to Participate (FISAP) Reporting Auditor Description of Condition and Effect. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items (information on eligible aid applicants) identified in the compliance supplement as critical information. As a result, the College is not in compliance with the Department of Education requirements that state the FISAP must be accurately reporting information. Auditor Recommendation. We recommend the College review their policies and procedures surrounding FISAP reporting. Corrective Action. The College is improving its documentation and retention processes to ensure all information used in preparing the annual FISAP report is fully supported and available for review. Moving forward, all data underlying the eight key line items identified in the compliance supplement will be saved, documented, and stored in a consistent and accessible manner. Information obtained from other departments will be retained in its original format, and any data extracted from PowerFAIDS or related systems will be saved at the time of report preparation. By implementing these documentation and retention procedures as standard operating practice, the College ensures FISAP submissions are accurate, verifiable, and compliant with federal audit requirements. Responsible Person. Jennifer Stimson, Director of Financial Aid Anticipated Completion Date. June 30, 2026
Ineligible Student Received Title IV Funding Auditor Description of Condition and Effect. During our testing, we noted that a student successfully appealed their academic dismissal in the Summer 2022–2023 semester. The student did not receive Title IV funding during that term and subsequently failed...
Ineligible Student Received Title IV Funding Auditor Description of Condition and Effect. During our testing, we noted that a student successfully appealed their academic dismissal in the Summer 2022–2023 semester. The student did not receive Title IV funding during that term and subsequently failed both attempted courses. Despite the lack of demonstrated academic improvement following the appeal, the student was awarded Title IV funding in the Spring 2024–2025 semester based on the appeal granted during the 2022–2023 academic year. As a result of this condition, one student received Title IV funding that who was not eligible based on the criteria outlined in the College's satisfactory academic policy (SAP). Auditor Recommendation. We recommend the College implement a formal review process to verify that students who were previously dismissed and granted an appeal in a prior academic year have demonstrated the required academic improvement before receiving subsequent Title IV funding, or alternatively, obtain a new appeal determination. Corrective Action. Management acknowledges this finding and is implementing strengthened Satisfactory Academic Progress (SAP) review procedures to ensure students who previously appealed an academic dismissal are properly evaluated before receiving Title IV funding. The Financial Aid Office is now working closely with the Registrar to ensure both Title‑IV and non‑Title‑IV students undergo appropriate SAP monitoring. Information Technology is developing a report that identifies students by financial‑aid track status, allowing Financial Aid to review aid‑receiving students while the Registrar evaluates all others. Students who require SAP follow‑up are contacted by the appropriate office, and SAP appeal forms are reviewed under updated criteria to ensure students demonstrate academic improvement before additional aid is awarded. These steps ensure the College remains compliant with federal SAP requirements and prevents ineligible students from receiving Title IV funds. Responsible Person. Jennifer Stimson, Director of Financial Aid Anticipated Completion Date. June 30, 2026
Finding 2025-003 Finding Summary: Some discrepancies were noted between the District and NSLDS. One student's data was not updated within the allowable time period. Responsible Individuals: Melissa Thornton, Financial Aid Manager Corrective Action Plan: We have worked within the department to ensure...
Finding 2025-003 Finding Summary: Some discrepancies were noted between the District and NSLDS. One student's data was not updated within the allowable time period. Responsible Individuals: Melissa Thornton, Financial Aid Manager Corrective Action Plan: We have worked within the department to ensure proper reporting on the financial aid systems. Anticipated Completion Date: July 1, 2026
The Registrar and Student Financial Aid Director will both ensure that any students that have updated their status are updated on a weekly basis. Registrar’s office will log into NSLDS to upload the file, and the CFO, Registrar, and Student Financial Aid Director will monitor updates monthly.
The Registrar and Student Financial Aid Director will both ensure that any students that have updated their status are updated on a weekly basis. Registrar’s office will log into NSLDS to upload the file, and the CFO, Registrar, and Student Financial Aid Director will monitor updates monthly.
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – 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 Student Loans – Assistance Listing No. 84.268 Federal...
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – 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 Student Loans – Assistance Listing No. 84.268 Federal TEACH Grant Program – Assistance Listing No. 84.379 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement additional 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: This is a repeat finding that was first presented to the University in conjunction with the release of the 2022 audit report in November 2023. While procedures had previously been implemented to address this issue, additional measures are being taken to ensure full compliance. The University will implement additional udates to its NSLDS reporting processes to ensure needed submissions are reported timely and accurately. Respective staff will receive additional training to ensure proper reporting to NSLDS occurs. Name(s) of the contact person(s) responsible for corrective action: Ms. Nacasaw Coppage, Director of Office of Financial Aid; Mr. Heath Burge, Assistant Vice President for Strategic Enrollment and Advising Services; and Mrs. Jeanese Outlaw-Gunter, University Registrar Planned completion date for corrective action plan: April 2026
Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds ar...
Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is evaluating its current Title IV funds procedures and implementing additional procedures to ensure timely return of refunds. This includes assigning additional staff to manage this process. Also, relevant staff have been reminded of the need to notify Financial Aid of student withdrawals timely. Name(s) of the contact person(s) responsible for corrective action: Ms. Nacasaw Coppage, Director of Office of Financial Aid Planned completion date for corrective action plan: March 2026
Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University must comply with 34 CFR 668.165(a). Condition: During our eligibility testing, 10 of 38 students who received Direct Loans were...
Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University must comply with 34 CFR 668.165(a). Condition: During our eligibility testing, 10 of 38 students who received Direct Loans were not notified of their disbursements timely by the University. Cause: The University did not have controls in place to ensure students were being notified of Direct Loan disbursements in a timely manner (within 30 days before or 30 days after crediting the students' account). Effect: The provisions of 34 CFR 668.165(a) were not followed and thus a total of 10 students were not notified of Direct Loan disbursements in a timely manner. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the University update their internal controls related to Direct Loan disbursements and send required communications prior to crediting the students' accounts. Corrective Actions Taken or Planned: We agree with this finding and recommendation. The financial aid office has automated the process to send disbursement notifications. Disbursement notifications are sent the day after loans are posted to a student’s account. Responsible Parties: Daniel Donner, Director of Financial Aid Completion Date: November 05, 2025
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