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Finding 524468 (2024-001)
Significant Deficiency 2024
The Colleges of Law
CA
Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303
Corrective Action Plan – The Colleges of Law Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Feder...
Corrective Action Plan – The Colleges of Law Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had one instance of excess cash for the Federal Direct Student Loan program, ranging from $172 to $10,314, from March 25, 2024, to April 5, 2024. Although the excess cash did not exceed the one-percent tolerance of prior year drawdowns, the funds were not returned within the required seven-day period. Summary: The College inadvertently retained excess cash for the Federal Direct Student Loan program beyond the seven-day tolerance period due to administrative oversight. The delay in returning the excess cash was attributed to the reconciliation process taking longer than anticipated. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure excess funds are returned to the Secretary within the seven-day tolerance period. 2. Process Change: The College will enhance its reconciliation process to expedite the identification and return of excess cash within the required timeframe. 3. Internal Control Strengthening: The College will implement more rigorous internal controls, including automated alerts and checks, to ensure compliance with cash management requirements. 4. Staff Training: Relevant staff will receive additional training on updated cash management procedures and the importance of timely returning excess cash. 5. Improved Monitoring: The College will introduce enhanced monitoring and tracking mechanisms to ensure that excess cash is promptly identified and returned within the mandated period. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024
View Audit 343821
Finding 524441 (2024-001)
Significant Deficiency 2024
McDaniel College and Subsidiary
MD
Questioned Costs Student Financial Aid Subrecipient Monitoring
Finding 2024-001 Condition Finding 2024-001 – Significant Deficiency – Return of Title IV Federal Program – Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency – U.S. Department of Education Pass- Through Entity – Not Applicable ALN Number – 84.063, 84.268 Federal Award Y...
Finding 2024-001 Condition Finding 2024-001 – Significant Deficiency – Return of Title IV Federal Program – Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency – U.S. Department of Education Pass- Through Entity – Not Applicable ALN Number – 84.063, 84.268 Federal Award Year – May 31, 2024 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. In addition, when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine, through a Return of Title IV Funds (R2T4) calculation, the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Corrective Action Plan Corrective Action Planned: {The College agrees with the finding and has taken immediate corrective action to address the finding related to R2T4 calculations. All R2T4 calculations for the related period have been recalculated and reviewed for accuracy. Any noted discrepancies related to the necessary return of funds have been addressed. Enhanced internal controls have been implemented to ensure that the dates entered in the Colleague system aligns with the academic calendar. The College will also institute an internal audit/compliance process for additional verification and monitoring. Identify the specific actions to be taken to eliminate or mitigate the recurrence of the finding. Name(s) of Contact Person(s) Responsible for Corrective Action: Kemia Himon, Financial Aid Director Anticipated Completion Date: 3.3.25
View Audit 343760 Questioned Costs: $1
Finding 524434 (2024-003)
Significant Deficiency 2024
Payne Theological Seminary
OH
Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking
Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in r...
Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The seminary will update our current WISP to comply with all requirements and updated standards. Name(s) of the contact person(s) responsible for corrective action: Raymond Ingram Planned completion date for corrective action plan: April 2025
View Audit 343723
Finding 524433 (2024-002)
Significant Deficiency 2024
Payne Theological Seminary
OH
Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties
Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary implemented a process to ensure credit balances are returned timely based on the regulations set forth by the Department of Education. Explanation of disagreement with audit finding: There is no disagreeme...
Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary implemented a process to ensure credit balances are returned timely based on the regulations set forth by the Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Through December 2024, Payne issues credits/refunds in two disbursements. In November 2024, the Business Office and Academic Services discussed moving to a single credit/refund disbursement in an effort to avoid potential delays in processing. A decision was made to approve the single credit/refund disbursement process effective Spring 2025. Financial Aid Services was notified and provided a new disbursement schedule. Communication of the change was sent to students November 30, 2024. Person responsible - Maryjo Lewis Planned completion date: The new process in effect beginning Spring 2025 term
View Audit 343723
Finding 524432 (2024-001)
Significant Deficiency 2024
Payne Theological Seminary
OH
Student Financial Aid Reporting Significant Deficiency
Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend the Seminary evaluate its procedures and policies around reporting Unsubsidized loan disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding:...
Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend the Seminary evaluate its procedures and policies around reporting Unsubsidized loan disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Business Office will post the awarded funds to the accounts in SONIS on the date designated on the disbursement roster. Name(s) of the contact person(s) responsible for corrective action: Razieh Adinehzadeh Planned completion date for corrective action plan: Changes implemented in February 2025.
View Audit 343723
Finding 524425 (2024-001)
Significant Deficiency 2024
Morehouse College
GA
Student Financial Aid Reporting Matching / Level of Effort / Earmarking
Finding No. 2024-001 SFA – Enrollment Reporting Federal Program Student Financial Assistance Cluster AL No. 84.268 Federal Direct Student Loans Federal Agency U.S. Department of Education Federal Award Years October 1, 2022 to September 30, 2023 October 1, 2023 to September 30, 2024 Criteri...
Finding No. 2024-001 SFA – Enrollment Reporting Federal Program Student Financial Assistance Cluster AL No. 84.268 Federal Direct Student Loans Federal Agency U.S. Department of Education Federal Award Years October 1, 2022 to September 30, 2023 October 1, 2023 to September 30, 2024 Criteria or Requirement Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS (OMB No. 1845-0035) (Pell, 34CFR 690.83(b)(2); FFEL, 34CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). Condition and Context During our test work, we selected a sample of 40 students that had enrollment status changes during fiscal year 2024. Within our sample, we identified 3 instances where the students’ enrollment status was not properly communicated to National Student Loan Data System (NSLDS). These instances involved students who reported their status changes to the College after the normal reporting period had ended. Cause and Potential Effect Noncompliance due to no control in place to identify late submissions of status changes and ensure that these changes are properly communicated to the NSLDS. This lack of control could result in inaccurate or delayed reporting of student status changes to the NSLDS, potentially affecting loan servicing and compliance with federal regulations. Questioned Cost There were no questioned cost associated with the finding. Corrective Action Plan to Finding 2024-001: Contact person for corrective action: LaKeidra Gilford – Interim Registrar Office of Records and Registration Corrective Action Plan: Morehouse College plan to implement the following to address finding No. 2024-001. • Office of Records and Registration will create a new policy effective July 1, 2025, that will state any medical withdrawals received after the last day of the current term will not be honored. • Office of Records and Registration effective May 2025 will continue the current process with additionally submitting two (2) additional graduation reports each month after the initial report is sent to National Student Clearinghouse to ensure all graduates are captured and reported.
View Audit 343696
Finding 524389 (2024-001)
Significant Deficiency 2024
Kansas Health Science Center, Inc.
IL
Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303
Corrective Action Plan – Kansas Health Science University Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, oth...
Corrective Action Plan – Kansas Health Science University Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: Kansas Health Science University (KHSU) had excess cash for the Federal Direct Student Loan program, including $268,278 from July 12, 2023, to July 19, 2023, and amounts ranging from $2,204 to $13,385 from April 8, 2024, to April 23, 2024. For the first period, the excess cash exceeded the one-percent tolerance of prior year drawdowns and was not returned within the three business-day period. For the second period, although the excess cash did not exceed the one-percent tolerance, amounts were not returned within the seven-day period as required. Summary: KHSU identified two instances of excess cash due to delays in returning unused funds. The Funds were not returned to ED withing the required number of days, leading to a violation of the federal cash management requirements. The issue was related to an administrative oversight related to the timing of the return of drawn funds. Corrective Action Planned or Taken: 1. Procedure Update: KHSU will update its cash management procedures to ensure compliance with both the three-day and seven-day return requirements for excess cash. 2. Process Change: KHSU will implement a process to immediately review and reconcile drawdowns with disbursement needs. Drawdowns will be based strictly on reconciled disbursement schedules to prevent excess cash. 3. Internal Control Strengthening: Internal controls will be enhanced to include automated alerts for identifying excess cash and triggering prompt corrective actions. 4. Staff Training: Financial aid and accounting staff will undergo targeted training on Federal cash management regulations, focusing on the prevention and timely resolution of excess cash. 5. Improved Monitoring: KHSU will establish daily monitoring of cash balances during peak disbursement periods and periodic reviews to ensure ongoing compliance with Federal regulations. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024
View Audit 343627
Chowan University
NC
Student Financial Aid Special Tests & Provisions Reporting
Name of Responsible Individual: Richard Todd, Registrar & Ruth Casper, Assistant Vice President of Student Financial Services Corrective Action: The University Financial Aid Office will work alongside the Registrar’s Office to identify and correct any enrollment reporting errors which may arise. Co...
Name of Responsible Individual: Richard Todd, Registrar & Ruth Casper, Assistant Vice President of Student Financial Services Corrective Action: The University Financial Aid Office will work alongside the Registrar’s Office to identify and correct any enrollment reporting errors which may arise. Corrections may include subsequent reporting to the Clearinghouse and/or manual reporting to NSLDS. Anticipated Completion Date: Ongoing
View Audit 343592
Finding 524341 (2024-002)
Significant Deficiency 2024
Bryn Mawr College
PA
Student Financial Aid Special Tests & Provisions Reporting
The College acknowledges that, while student status change information was being sent to the NSC, it did not have an appropriate process in place to regularly review and reconcile the data received by the NSLDS and information for 2 students was not properly remitted. A correction was made to the e...
The College acknowledges that, while student status change information was being sent to the NSC, it did not have an appropriate process in place to regularly review and reconcile the data received by the NSLDS and information for 2 students was not properly remitted. A correction was made to the existing reconciliation report so that all statuses remitted to the NSLDS are captured accurately and can be reconciled by the Registrar’s Office to the College’s enrollment records. Additionally, the College will adopt a practice of manually updating the NSC after receiving each student status change notification throughout the semester. The Planned Corrective Action will be implemented immediately.
View Audit 343564
Finding 524316 (2024-001)
Significant Deficiency 2024
Iona College
NY
Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking
FINDING 2024-001 Name of Responsible Individual: Daniel Arndt, Registrar Corrective Action: Management acknowledges the finding regarding the inaccurate reporting of student data elements under the Program-Level record on the NSLDS website. To address this issue, the University has implemented a cor...
FINDING 2024-001 Name of Responsible Individual: Daniel Arndt, Registrar Corrective Action: Management acknowledges the finding regarding the inaccurate reporting of student data elements under the Program-Level record on the NSLDS website. To address this issue, the University has implemented a corrective action plan that includes updating our reporting frequency and enhancing our data review processes: Updated Reporting Frequency: As of January 2025, the University now includes the non-compulsory terms, summer 1 and winter sessions, in its reporting. Previous institutional practice did not include reporting program level data for these terms given that said terms do not involve federal financial aid. This change ensures that all Program-Level data, regardless of federal financial aid involvement, is accurately reported. Secondary Check Process: Each month, the Compliance Officer will review a sample of 100 students from NSLDS to verify significant data elements, including program enrollment effective dates. After the initial review, the Compliance Officer will summarize the findings and share them with the Associate Registrar and Registrar for a secondary review. Any necessary edits will be made, followed by a review of an additional 25 students to ensure accuracy. We believe these corrective action steps are critical to ensuring accurate reporting and preventing this issue in the future. Anticipated Completion Date: January 31, 2025
View Audit 343512
Finding 524210 (2024-006)
Significant Deficiency 2024
Montcalm Community College
MI
Matching / Level of Effort / Earmarking Student Financial Aid Reporting § 200.303
2024-006 – Common Origination and Disbursement (COD) Reporting. Auditor Description of Condition and Effect. During our testing of COD reporting, we identified one of 40 disbursements was not reported to COD within 15 days of the disbursement date. A lack of timely reporting may prevent the College ...
2024-006 – Common Origination and Disbursement (COD) Reporting. Auditor Description of Condition and Effect. During our testing of COD reporting, we identified one of 40 disbursements was not reported to COD within 15 days of the disbursement date. A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Auditor Recommendation. We recommend that the College evaluate and enhance its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Corrective Action. I have a procedure in place to report graduates as soon as they are confirmed with academics. Responsible Party. Financial Aid Director, Jennifer Stimson. Anticipated Completion Date. January 2025.
View Audit 343397
Finding 524208 (2024-005)
Significant Deficiency 2024
Montcalm Community College
MI
Student Financial Aid Allowable Costs / Cost Principles Eligibility
2024-005 – Pell Grant Calculation. Auditor Description of Condition and Effect. One student out of the twenty five Pell grants tested was found to be under awarded based on the enrollment status and cost of attendance. As a result of this condition, the College was exposed to an increased risk that ...
2024-005 – Pell Grant Calculation. Auditor Description of Condition and Effect. One student out of the twenty five Pell grants tested was found to be under awarded based on the enrollment status and cost of attendance. As a result of this condition, the College was exposed to an increased risk that incorrect information would be used to determine students' Pell Grant award amounts. Auditor Recommendation. We recommend the College implement procedures to ensure the COA and EFC used to calculate each student's Pell Grant is updated for each academic year and reviewed by an independent official. Corrective Action. This is corrected on setup and noted to correct the COA. Responsible Party. Financial Aid Director, Jennifer Stimson. Anticipated Completion Date. March 2025 - next set up, it was corrected for 24/25 academic year in May 2024.
View Audit 343397
Finding 524203 (2024-004)
Significant Deficiency 2024
Montcalm Community College
MI
Student Financial Aid Reporting Significant Deficiency
2024-004 – 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 identified in the compliance supplement as critica...
2024-004 – 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 identified in the compliance supplement as critical information. 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. Adjust notes on the procedure (or guidelines), laying out the complete steps of FISAP to ensure the data is accurate. Responsible Party. Financial Aid Director, Jennifer Stimson. Anticipated Completion Date. February 2025 - the next FISAP.
View Audit 343397
Finding 524198 (2024-003)
Significant Deficiency 2024
Montcalm Community College
MI
Reporting Special Tests & Provisions Student Financial Aid
2024-003 – Timeliness of Status Change Reporting. Auditor Description of Condition and Effect. It was noted during our testing of 13 students with status changes, two instances of late reporting of status changes. Both of these instances were fall graduates whose status change was not reported withi...
2024-003 – Timeliness of Status Change Reporting. Auditor Description of Condition and Effect. It was noted during our testing of 13 students with status changes, two instances of late reporting of status changes. Both of these instances were fall graduates whose status change was not reported within the required timeframe. As a result of this condition, the NSLDS had incorrect records of the enrollment status of students. Auditor Recommendation. We recommend the College reviews the status change reporting requirements and implement procedures to ensure that the status changes are being reported to the NSLDS in a timely manner. Corrective Action. To view graduated student's as soon as they have been processed. Responsible Party. Financial Aid Director, Jennifer Stimson. Anticipated Completion Date. November 2024.
View Audit 343397
Finding 524193 (2024-002)
Significant Deficiency 2024
Montcalm Community College
MI
Special Tests & Provisions Student Financial Aid Reporting
2024-002 – Return of Title IV (R2T4) Calculation. Auditor Description of Condition and Effect. During our testing of six students with Return of Title IV amounts, we noted that the College did not exclude the correct amount of days for scheduled breaks of five days or more in both the fall 2023 and ...
2024-002 – Return of Title IV (R2T4) Calculation. Auditor Description of Condition and Effect. During our testing of six students with Return of Title IV amounts, we noted that the College did not exclude the correct amount of days for scheduled breaks of five days or more in both the fall 2023 and spring 2024 terms, resulting in the incorrect Return of Title IV calculation for all students tested. As a result of this condition, the students' return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount. Auditor Recommendation. We recommend the College review the Return of Title IV requirements and implement procedures to ensure the Return of Title IV calculations are using the correct amount of term days and are completed accurately. Corrective Action. This has been noted in setup notes, so the number of days are correct going forward. Responsible Party. Financial Aid Director, Jennifer Stimson. Anticipated Completion Date. November 2024.
View Audit 343397
Warren Wilson College
NC
Student Financial Aid Subrecipient Monitoring Reporting
Corrective Action Plan from College: This is submitted to Derrick Everhart, Director of Financial Aid, by the College Registrar Brooke Millsaps. In order to correct the need to have a monitoring mechanism in place, the College has taken the following actions: ● Warren Wilson College convened a group...
Corrective Action Plan from College: This is submitted to Derrick Everhart, Director of Financial Aid, by the College Registrar Brooke Millsaps. In order to correct the need to have a monitoring mechanism in place, the College has taken the following actions: ● Warren Wilson College convened a group of stakeholders to review our exit and withdrawal procedures. This group included representatives from the following offices: Financial Aid, Registrar, tudent Accounts, Student Engagement, Office of the Provost. ● The group revised our procedures when a student indicates they want to leave the College. These revised procedures include the following: 1. Developed a specific chart to determine the classification of the student, the time of year of the action, and the circumstances of the action: See Corrective Action Plan for chart / table. 2. Removed a student's ability to complete the exit form once classes started in order to prevent an erroneous student exit 3. Implemented an Administrative Exit - census verification process . This allows the college the opportunity to verify through roster verification, work participation, and residential status if a student should be administratively exited. 4. As a result of this revised institutional procedure, the Office of the Registrar reviewed and revised its procedures regarding exits and withdrawals to ensure that we are documenting accurate information in the appropriate locations within Jenzabar. This will ensure that when we report data to the National Student Clearinghouse, the associated exits and withdrawal dates are in alignment. Management Response : The Director of Financial Aid concurs with this finding and noted while the College was out of compliance with the reporting timeframe, the College did make a substantial effort to complete the requirements and follow up with NSLDS and NSC to correct the students enrollment. Contact College personnel for corrective action. Derrick Everhart, Director of Financial Aid deverhart@warren-wilson.edu Brooke Milsaps, College Registrar bmillsaps@warren-wilson.edu
View Audit 343264
Finding 524036 (2024-005)
Significant Deficiency 2024
Metro Technology Center
OK
Student Financial Aid Eligibility Significant Deficiency
Finding Summary: U.S. Department of Education Student Financial Aid Cluster (FAL # 84.268, 84.063) Eligibility Significant Deficiency in Internal Control over Compliance Responsible Individuals: Alicia Smith, Director of Financial Aid Corrective Action Plan: The process has been adjusted to ensure m...
Finding Summary: U.S. Department of Education Student Financial Aid Cluster (FAL # 84.268, 84.063) Eligibility Significant Deficiency in Internal Control over Compliance Responsible Individuals: Alicia Smith, Director of Financial Aid Corrective Action Plan: The process has been adjusted to ensure manual calculations are done independently by two different people. Anticipated Completion Date: July 1, 2025
View Audit 343223
Finding 524031 (2024-004)
Significant Deficiency 2024
Metro Technology Center
OK
Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking
Finding Summary: U.S. Department of Education Student Financial Aid Cluster (FFAL #84.268 and #84.063) Special Test: Return of Funds Significant Deficiency in Internal Control over Compliance Responsible Individuals: Alicia Smith, Director of Financial Aid Corrective Action Plan: The process has bee...
Finding Summary: U.S. Department of Education Student Financial Aid Cluster (FFAL #84.268 and #84.063) Special Test: Return of Funds Significant Deficiency in Internal Control over Compliance Responsible Individuals: Alicia Smith, Director of Financial Aid Corrective Action Plan: The process has been adjusted to ensure manual calculations are done independently by two different people. Anticipated Completion Date: July 1, 2025
View Audit 343223
Finding 524021 (2024-005)
Significant Deficiency 2024
Northwestern Health Sciences University
MN
Student Financial Aid Matching / Level of Effort / Earmarking Significant Deficiency § 200.303
Documentation of Review Recommendation: We recommend the University reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: F...
Documentation of Review Recommendation: We recommend the University reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid will send a reconciliation to the Controller by the 10th business day. The controller will review and approve by the 15th business day. Name of the contact person responsible for corrective action: Scott Roelke, Director of Financial Aid Planned completion date for corrective action plan: 2/4/2025
View Audit 343204
Finding 524016 (2024-004)
Significant Deficiency 2024
Northwestern Health Sciences University
MN
Questioned Costs Student Financial Aid Significant Deficiency
Return of Title IV Funds Recommendation: We recommend the University review the R2T4 calculations and the term dates used. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university will manually review student...
Return of Title IV Funds Recommendation: We recommend the University review the R2T4 calculations and the term dates used. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university will manually review student registration begin and end dates for all students where withdrawal records indicate a R2T4 calculation may be required. This review will ensure appropriate dates are used for determining the need for a R2T4 calculation, and for student records requiring a R2T4 calculation, that the calculation is completed using the correct number of days. Name of the contact person responsible for corrective action: Scott Roelke, Director of Financial Aid Planned completion date for corrective action plan: In place as of February 14, 2025.
View Audit 343204 Questioned Costs: $1
Finding 524015 (2024-003)
Significant Deficiency 2024
Northwestern Health Sciences University
MN
Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking
Perkins Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to findin...
Perkins Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the audit finding where some MPNs are missing. We are unable to correct the past but moving forward, the new ones are being retained. Name of the contact person responsible for corrective action: Jane Garner, CFO Planned completion date for corrective action plan: Already in place
View Audit 343204
Finding 524010 (2024-002)
Significant Deficiency 2024
Northwestern Health Sciences University
MN
Student Financial Aid Reporting Significant Deficiency
National Student Loan Data System (NSLDS) Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”. Explanation of disagreement with audit finding: There is no disagr...
National Student Loan Data System (NSLDS) Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Although the Colleague data is correct, the logic in Colleague used to send the files to the NSC is excluding records when the student is not registered for classes in the month an action such as graduation or withdrawal occurs. In that situation the NSC is inserting default dates onto the record based on the last date of their classes in the prior term. We are working with our IT team & Ellucian on an approach to update that logic. In the meantime, we will implement a reporting solution to allow manual correction of these issues. Name of the contact person responsible for corrective action: Kris Ragozzino, Registrar Planned completion date for corrective action plan: Already in place.
View Audit 343204
Finding 523967 (2024-001)
Significant Deficiency 2024
Goucher College
MD
Student Financial Aid Reporting Matching / Level of Effort / Earmarking
Finding 2024-001 Condition Condition: The change in student status for 25 of the 25 students tested was not reported to the National Student Loan Data Systems (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, these students were ultimately reported to the N...
Finding 2024-001 Condition Condition: The change in student status for 25 of the 25 students tested was not reported to the National Student Loan Data Systems (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, these students were ultimately reported to the NSLDS. Corrective Action Plan The Director of Student Financial Services and the Registrar resolved the issue that caused delayed enrollment changes being submitted to NSLDS due to turnover. The Office of the Registrar identified the errors in the National Student Clearinghouse reporting. They worked internally with our IT department to pinpoint the errors resulting in delays in submission to the National Student Loan Database Systems (NSLDS) via the National Student Clearinghouse. The Office of the Registrar submitted overdue files to the National Clearinghouse in conjunction with the Senior Director of Information Technology to ensure all technical requirements are met. These updates and alignments should bring late reporting to zero. As of January 2025, all prior term file submissions have been submitted to the National Student Clearinghouse. Name of Contact Person Responsible for Corrective Action: Elizabeth Brentzel Anticipated Completion Date: Winter 2025
View Audit 343152
MacCormac College Dba Generations College
IL
Student Financial Aid Matching / Level of Effort / Earmarking Reporting
Finding 2024-004 Student Financial Aid Cluster, CFDA # 84.063, 84.268 Condition: The College did not report the actual disbursement date that students receive the Direct Loan and/or Pell Funds to the COD system. Corrective Action Plan: ...
Finding 2024-004 Student Financial Aid Cluster, CFDA # 84.063, 84.268 Condition: The College did not report the actual disbursement date that students receive the Direct Loan and/or Pell Funds to the COD system. Corrective Action Plan: Objective: To ensure the Financial Aid office reports the actual disbursement date the student receives the Direct Loan and/or Pell funds to the COD system. Corrective Actions: 1. Establish a Standard Operating Procedure (SOP) for reporting disbursement dates 2. Implement an automated system for disbursement reporting 3. Training for Financial Aid and Accounting staff 4. Coordination between relevant departments 5. Verification and reconciliation process 6. Review and monitor data submissions 7. Establish a process for correcting disbursement errors 8. Ongoing monitoring and follow-up Monitoring and Follow-Up: The Financial Aid Office will be responsible for ensuring the implementation of this corrective action plan and will provide monthly updates to senior management. Person(s) Responsible for Corrective Action Plan: Jamieta Hoskins, Director of Financial Aid Anticipated Completion Date for Corrective Action Plan: March 31, 2025
View Audit 343124
MacCormac College Dba Generations College
IL
Student Financial Aid Reporting Matching / Level of Effort / Earmarking
Finding 2024-002 Student Financial Aid Cluster, Assistance Listing # 84.063, 84.268 Condition: The College did not send changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Corrective Action ...
Finding 2024-002 Student Financial Aid Cluster, Assistance Listing # 84.063, 84.268 Condition: The College did not send changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Corrective Action Plan: Objective: To ensure the timely reporting of changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled, to the National Student Loan Data Center (NSLDS) within 60 days of the change. Corrective Actions: 1. Review and update internal policies and procedures 2. Training and education for relevant staff 3. Implement a tracking and monitoring system 4. Conduct regular audits and monitoring 5. Collaborate with NSLDS for support and guidance Monitoring and Follow-Up: • The College’s Financial Aid Office will track the implementation of this Corrective Action Plan and provide monthly progress updates to senior management. • The College will conduct periodic reviews and evaluations to ensure that the plan’s objectives are being met and that the institution remains in full compliance with the Department of Education’s reporting requirements. Person(s) Responsible for Corrective Action Plan: Jamieta Hoskins, Director of Financial Aid Anticipated Completion Date for Corrective Action Plan: February 28, 2025
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