Corrective Action Plans

Finding 391250 (2023-004)

Significant Deficiency 2023

NJ

Questioned Costs Student Financial Aid Significant Deficiency

Unofficial Withdrawals Planned Corrective Action: The University will run zero credit reports at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. Person Responsible for Corrective Action Plan: Nicholas Cap...

Unofficial Withdrawals Planned Corrective Action: The University will run zero credit reports at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: June 30th, 2024

View Audit 301872 Questioned Costs: $1

Finding 391248 (2023-003)

Significant Deficiency 2023

Saint Elizabeth University

NJ

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The University’s Financial Aid Office will update the anticipated disbursement date to reflect the actual disbursement for 2022-23. We will review the current award year to ensure that the anticipated disbursement dates...

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The University’s Financial Aid Office will update the anticipated disbursement date to reflect the actual disbursement for 2022-23. We will review the current award year to ensure that the anticipated disbursement dates reflect the actual disbursement date. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: April 30, 2024

View Audit 301872

Finding 391151 (2023-003)

None 2023

Ohio Institute of Allied Health, Inc.

IL

Questioned Costs Eligibility Student Financial Aid

FINDING 2023-3- Overawarded Federal Direct Loan Amounts The Institute had not correctly calculated the federal loan eligibility for two (2) students. A.Comments on Findings and Recommendations: The Institute agrees with the finding and Auditor's recommendation. B.Actions Taken or Planned Previous FA...

FINDING 2023-3- Overawarded Federal Direct Loan Amounts The Institute had not correctly calculated the federal loan eligibility for two (2) students. A.Comments on Findings and Recommendations: The Institute agrees with the finding and Auditor's recommendation. B.Actions Taken or Planned Previous FA administrator failed to consistently calculate student enrollment hours. This caused incorrect loan awards to be prorated and disbursed. We have revised our method of requesting aid and the enrollment status of each student will be verified individually prior to requesting loans. We have also removed FA administrator (effective 12/2023) and third-party servicer from their role (effective 4/2024). We will be returning $1,056 to the Department of Education. Signed Betsy Bremke, Administrative Campus Director Date: _3/29/2024__

View Audit 301753 Questioned Costs: $1

Finding 391149 (2023-007)

None 2023

Ohio Institute of Allied Health, Inc.

IL

Questioned Costs Special Tests & Provisions Student Financial Aid

FINDING 2023-7- Refund Made in Improper Sequence The Institute had incorrectly calculated the order in which Title IV refunds were to go back A.Comments on Findings and Recommendations: The Institute agrees with the finding and Auditor's recommendation. B.Actions Taken or Planned We have contracted ...

FINDING 2023-7- Refund Made in Improper Sequence The Institute had incorrectly calculated the order in which Title IV refunds were to go back A.Comments on Findings and Recommendations: The Institute agrees with the finding and Auditor's recommendation. B.Actions Taken or Planned We have contracted with a new third-party servicer that will immediately process R2T4. This will remove any compliance issue with the order refunds. Previous FA admin whom assumed this role has been removed. We will be refunding $2,811 to the Department of Education and crediting $2,563 to the students' accounts that were affected. Signed Betsy Bremke, Administrative Campus Director Date: _3/29/2024__

View Audit 301753 Questioned Costs: $1

Finding 391148 (2023-006)

None 2023

Ohio Institute of Allied Health, Inc.

IL

Questioned Costs Special Tests & Provisions Student Financial Aid

FINDING 2023-6- Late Refunds of Title IV The Institute had not processed the Title IV refunds due within 45 days of DOD on three (3) students. A.Comments on Findings and Recommendations: The Institute agrees with the finding and Auditor's recommendation. B.Actions Taken or Planned We have contracted...

FINDING 2023-6- Late Refunds of Title IV The Institute had not processed the Title IV refunds due within 45 days of DOD on three (3) students. A.Comments on Findings and Recommendations: The Institute agrees with the finding and Auditor's recommendation. B.Actions Taken or Planned We have contracted with a new third-party servicer that will immediately take back funding once R2T4 is processed. This will remove the delay in communication from the accounting department to refund funding through manual process. Signed Betsy Bremke, Administrative Campus Director Date: _3/29/2024__

View Audit 301753 Questioned Costs: $1

Finding 391147 (2023-005)

Significant Deficiency 2023

Ohio Institute of Allied Health, Inc.

IL

Questioned Costs Special Tests & Provisions Student Financial Aid

FINDING 2023-5- Incorrect Refund Calculations The Institute had not correctly calculated the Return-to-Title IV for four (4) students who had withdrawn from the Institute. A.Comments on Findings and Recommendations: The Institute agrees with the finding and Auditor's recommendation. B.Actions Taken ...

FINDING 2023-5- Incorrect Refund Calculations The Institute had not correctly calculated the Return-to-Title IV for four (4) students who had withdrawn from the Institute. A.Comments on Findings and Recommendations: The Institute agrees with the finding and Auditor's recommendation. B.Actions Taken or Planned We will complete R2T4 Calculations correctly and return the unearned aid back to Dept of Education promptly. We have also moved all R2T4 calculation to a new third-party servicer as of 4/2024. We will be returning $953 to the Department of Education and crediting $3,569 to the students' accounts that were affected. Signed Betsy Bremke, Administrative Campus Director Date: _3/29/2024__

View Audit 301753 Questioned Costs: $1

Finding 391146 (2023-004)

Material Weakness 2023

Ohio Institute of Allied Health, Inc.

IL

Questioned Costs Student Financial Aid Subrecipient Monitoring

FINDING 2023-4- Untimely Paid and Unpaid Credit Balances The Institute had Untimely Paid and Unpaid Credit Balances while Participating under the Zone Alternative and the Heightened Cash Monitoring 1 Payment Method A.Comments on Findings and Recommendations: The Institute agrees with the finding and...

FINDING 2023-4- Untimely Paid and Unpaid Credit Balances The Institute had Untimely Paid and Unpaid Credit Balances while Participating under the Zone Alternative and the Heightened Cash Monitoring 1 Payment Method A.Comments on Findings and Recommendations: The Institute agrees with the finding and Auditor's recommendation. B.Actions Taken or Planned We have revised the process of student stipends ofdisbursements. Each student whose account receives a disbursement whom results in a credit balance, will be given stipend prior to any draw down. We shall also make process and procedures with new third-party servicer to ensure stipend is sent prior to drawdown. Signed Betsy Bremke, Administrative Campus Director Date: _3/29/2024__

View Audit 301753 Questioned Costs: $1

Finding 391145 (2023-002)

Significant Deficiency 2023

Ohio Institute of Allied Health, Inc.

IL

Eligibility Student Financial Aid Significant Deficiency

FINDING2023-2- Incorrect Pell Grants The Institute incorrectly calculated Pell Grants for thirteen (13) students. A.Comments on Findings and Recommendations: The Institute agrees with the finding and Auditor's recommendation. B.Actions Taken or Planned Previous FA administrator failed to consistentl...

FINDING2023-2- Incorrect Pell Grants The Institute incorrectly calculated Pell Grants for thirteen (13) students. A.Comments on Findings and Recommendations: The Institute agrees with the finding and Auditor's recommendation. B.Actions Taken or Planned Previous FA administrator failed to consistently update student enrollment status in software. This caused incorrect Pell awards to be requested and disbursed. We have revised our method of requesting aid and the enrollment status of each student will be verified individually prior to requesting Pell. We have also removed FA administrator (effective 12/2023) and third-party servicer from their role (effective 4/2024). We will be refunding $3,097 to the Department of Education and crediting $4,239 to the affected student accounts. Signed Betsy Bremke, Administrative Campus Director Date: _3/29/2024__

View Audit 301753

Finding 391128 (2023-005)

Material Weakness 2023

Sioux Falls School District 49-5

SD

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Identifying Number: 2023-005: U.S. Department of Education: Student Financial Aid Cluster – 84.268, Federal Direct Student Loans Finding: The following instances were identified during testing of enrollment reporting: 7 instances in which a student’s status change was certified outside the 60-day re...

Identifying Number: 2023-005: U.S. Department of Education: Student Financial Aid Cluster – 84.268, Federal Direct Student Loans Finding: The following instances were identified during testing of enrollment reporting: 7 instances in which a student’s status change was certified outside the 60-day reporting requirement, 7 instances in which a student’s status change was not reported within 60 days to the National Student Loan Data System (NSLDS) nor included in reporting to the National Student Clearinghouse (NSC), and 2 instances in which a student’s program start date reported in NSLDS did not agree with student records. Corrective Action Taken or Planned: The STC Financial Aid Office and Registrar will work to develop a process to review errors in the three systems that are involved in enrollment status reporting and identify any solutions. A common folder for submittal rosters will be shared between the offices so that they may also be reviewed for accuracy. National Student Clearinghouse issue notifications will also be kept on file for future reference. Contact person: Rich Kluin, Vice President – Finance and Operations, Southeast Technical College Status of finding – The above corrective actions will be implemented beginning July 1, 2024.

View Audit 301715

Finding 391127 (2023-004)

Significant Deficiency 2023

Sioux Falls School District 49-5

SD

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

Identifying Number: 2023-004: U.S. Department of Education: Student Financial Aid Cluster – 84.268, Federal Direct Student Loans Finding: During testing of disbursement notifications, one student did not receive the notification in a timely manner. Corrective Action Taken or Planned: STC Financial A...

Identifying Number: 2023-004: U.S. Department of Education: Student Financial Aid Cluster – 84.268, Federal Direct Student Loans Finding: During testing of disbursement notifications, one student did not receive the notification in a timely manner. Corrective Action Taken or Planned: STC Financial Aid Office will continue to monitor disbursements and work to create a report of notifications sent or errors so that notifications are not missed. Contact person: Micah Hansen, Director of Financial Aid, Southeast Technical College Status of finding – The above corrective actions will be implemented beginning July 1, 2024.

View Audit 301715

Finding 391126 (2023-003)

Significant Deficiency 2023

Sioux Falls School District 49-5

SD

Questioned Costs Student Financial Aid Subrecipient Monitoring

Identifying Number: 2023-003: U.S. Department of Education: Student Financial Aid Cluster – 84.268, Federal Direct Student Loans Finding: For one student out of 61 students tested, an incorrect amount of subsidized and unsubsidized loan was awarded. Corrective Action Taken or Planned: STC Financial ...

Identifying Number: 2023-003: U.S. Department of Education: Student Financial Aid Cluster – 84.268, Federal Direct Student Loans Finding: For one student out of 61 students tested, an incorrect amount of subsidized and unsubsidized loan was awarded. Corrective Action Taken or Planned: STC Financial Aid Office will request a list of Build Dakota students and estimated scholarship amounts at the beginning of the academic year. This information will be added into the student’s financial aid packaging formula to review for potential changes needed in federal aid awards. Once the Business Office has completed applying Build Dakota funds for the term, the information will be shared with the Financial Aid Office to make adjustments to the original estimates used. Contact person: Micah Hansen, Director of Financial Aid, Southeast Technical College Status of finding – The above corrective actions will be implemented beginning July 1, 2024.

View Audit 301715 Questioned Costs: $1

Finding 391125 (2023-012)

Significant Deficiency 2023

State of Iowa

IA

Allowable Costs / Cost Principles Student Financial Aid

The Department will retrain staff on when an overpayment is needed, when to cancel a case and what to look for in the system when an alert is received about a child entering foster care. A reminder will be provided to all Income Maintenance staff providing the policies and procedures for duplicate ...

The Department will retrain staff on when an overpayment is needed, when to cancel a case and what to look for in the system when an alert is received about a child entering foster care. A reminder will be provided to all Income Maintenance staff providing the policies and procedures for duplicate benefits. This reminder will be emailed and also discussed at team staff meetings.

View Audit 301710

Finding 390876 (2023-001)

Significant Deficiency 2023

Spring Hill College

AL

Student Financial Aid Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles

(Repeat) Federal Direct Student Loans, ALN 84.268; Grant period—Year ended June 30, 2023 Condition: There was lack of documentation related to disbursement notices and exit counseling for eight out of thirty-four students tested. Criteria: According to §668.165, before an institution disburses tit...

(Repeat) Federal Direct Student Loans, ALN 84.268; Grant period—Year ended June 30, 2023 Condition: There was lack of documentation related to disbursement notices and exit counseling for eight out of thirty-four students tested. Criteria: According to §668.165, before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. Additionally, according to §682.604, a school must ensure that exit counseling is conducted with each loan borrower and graduate either in person, by audiovisual presentation, or by interactive electronic means. Cause: The College was unable to locate the documents for the students as a result of transitioning softwares. Effect: Certain documentation for disbursement notices and exit counseling was lost during the transition of the College's software. Context: During the compliance audit testing of ALN 84.268, it was determined that documentation to confirm delivery of disbursement notices and performance of exit counseling could not be provided for certain students selected for testing. Recommendation: We recommend all required documentation be backed up to support compliance with certain requirements. View of Responsible Officials and Planned Corrective Action: The College is currently working with their IT department to make sure that all types of communication includes copying the financial aid department email to make sure the College has support for all communications to prevent this in the future.

View Audit 301577

Finding 390641 (2023-220)

None 2023

State of Idaho

ID

Questioned Costs Student Financial Aid Eligibility

Finding Number 2023-220: The Department failed to provide necessary supporting documentation for five Adoption Assistance Title IV-E eligibility determinations. Federal Programs: 93.659 – Adoption Assistance Related to Prior Finding: N/A Agency’s view: The Department agrees with this finding. ...

Finding Number 2023-220: The Department failed to provide necessary supporting documentation for five Adoption Assistance Title IV-E eligibility determinations. Federal Programs: 93.659 – Adoption Assistance Related to Prior Finding: N/A Agency’s view: The Department agrees with this finding. Corrective Action: The department agrees with the finding related to the critical importance of obtaining and maintaining documentation for all necessary background checks. Although the department was ultimately able to verify background checks were completed, we agree that we were unable to readily pull the needed documentation on these in a timely manner. The department will assure supporting documentation for Adoption Assistance Title IV-E eligibility determinations are maintained within the electronic filing system by adding an additional verification to the current process. When a supervisor reviews a departmental adoption for finalization, they will verify that a copy of the Enhanced Criminal History Background clearance letter for all adults residing in the home is uploaded to the prospective adoptive parents’ profile in eCabinet (the electronic case management system), and the signed copy of the adoption assistance agreement is uploaded to the child’s profile. The application process for Adoption Assistance Title IV-E eligibility for private adoptions will be updated to include the addition of the Enhanced Criminal History Background clearance letters for all adults residing in the home to the child’s eCabinet file. When a supervisor approves an adoption assistance agreement for a private adoption, they will verify a copy of the signed adoption assistance agreement is uploaded to the adoptive child’s profile. This will be completed by August 2024. Anticipated Corrective Action Date: August 2024 Responsible for Corrective Action: Cameron Gilliland, Division Administrator Cameron.Gilliland@dhw.idaho.gov 208-334-0641 Kelly Combs, Bureau Chief, Compliance Kelly.Combs@dhw.idaho.gov 208-334-5814

View Audit 301345 Questioned Costs: $1

Finding 390639 (2023-218)

None 2023

State of Idaho

ID

Questioned Costs Student Financial Aid Eligibility

Finding Number 2023-218: The Department failed to provide necessary documentation to support the eligibility determination for two foster care providers within the Foster Care -Title IV—E program. Federal Programs: 93.658 – Foster Care Title IV-E Related to Prior Finding: N/A Agency’s view: The D...

Finding Number 2023-218: The Department failed to provide necessary documentation to support the eligibility determination for two foster care providers within the Foster Care -Title IV—E program. Federal Programs: 93.658 – Foster Care Title IV-E Related to Prior Finding: N/A Agency’s view: The Department agrees with this finding. Corrective Action: The department agrees with the finding related to the critical importance of obtaining and maintaining documentation for all necessary background checks. Although the department was ultimately able to verify background checks were completed, we agree that we were unable to readily pull the needed documentation on these in a timely manner. To correct the issue, the department will add an additional point of verification that the Enhanced Criminal History Background Check clearance letter from the Background Check Unit’s system is uploaded to eCabinet, by having supervisors view the document within eCabinet prior to approving the initial foster care license. Supervisors will also confirm that all ICPC home studies address results of background checks for all adults in the home and any additional potential caregivers. This will be completed April 2024. Anticipated Corrective Action Date: April 2024 Responsible for Corrective Action: Cameron Gilliland, Division Administrator Cameron.Gilliland@dhw.idaho.gov 208-334-0641 Kelly Combs, Bureau Chief, Compliance Kelly.Combs@dhw.idaho.gov 208-334-5814

View Audit 301345 Questioned Costs: $1

Finding 390638 (2023-217)

Material Weakness 2023

State of Idaho

ID

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Student Financial Aid § 200.303

Finding Number 2023-217: The Department does not have documented internal controls for adjustments processed to the Foster Care -Title IV—E program. Federal Programs: 93.658 – Foster Care Title IV-E Related to Prior Finding: N/A Agency’s view: The Office agrees with this finding. Corrective Act...

Finding Number 2023-217: The Department does not have documented internal controls for adjustments processed to the Foster Care -Title IV—E program. Federal Programs: 93.658 – Foster Care Title IV-E Related to Prior Finding: N/A Agency’s view: The Office agrees with this finding. Corrective Action: The Department will continue to record adjustment activity through Help Desk tickets, SharePoint documentation, and ESPI. The Department will ensure improved visibility to the adjustment and approval process and documentation by ensuring all roles who need access (including auditors), have access to all relevant systems and storage locations such as access to SharePoint and Help Desk tickets. This step will be completed by April 30, 2024. Anticipated Corrective Action Date: April 30, 2024 Responsible for Corrective Action: Cameron Gilliland, Division Administrator Cameron.Gilliland@dhw.idaho.gov 208-334-0641 Kelly Combs, Bureau Chief, Compliance Kelly.Combs@dhw.idaho.gov 208-334-5814

View Audit 301345

Finding 390571 (2023-003)

Significant Deficiency 2023

Lemoyne-Owen College

TN

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Finding 2023-003 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiency): We observed the following condition in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: • The College fai...

Finding 2023-003 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiency): We observed the following condition in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: • The College failed to submit their Crime and Safety report for testing. The College should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. Corrective Action – A new CFO has been hired and is in the process of reorganizing Financial Aid Office operations, hiring additional staff, and training existing staff.

View Audit 301332

Finding 390567 (2023-002)

Significant Deficiency 2023

Lemoyne-Owen College

TN

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Finding 2023-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiencies): We observed the following condition in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: • The College h...

Finding 2023-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiencies): We observed the following condition in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: • The College had differences in the following programs which were not reconciled to the general ledger: Federal Work Study, Federal Pell Grant and Federal Supplemental Educational Opportunity Grant (SEOG), which caused unreconciled data to be used on the Fiscal Operations Report and Application to Participate (FISAP). Citation: SFA handbook Ch. 5 CFR668.161 – 668.176. The College should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. Corrective Action – A new CFO and financial aid director have been hired. The CFO is in the process of reorganizing Business Office operations, hiring additional staff, and training existing staff to ensure the monthly reconciliations of all programs and accurate completion of required federal reports. The financial aid director as well as the controller will be responsible for maintenance of those monthly reconciliations.

View Audit 301332

Finding 390552 (2023-005)

Significant Deficiency 2023

Wilberforce University

OH

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility

Views of Responsible Officials and Planned Corrective Actions: Management agrees with the auditors and has initiated the necessary corrective action plan to mitigate the deficiency from occurring again. The plan is to implement new procedures to ensure the reporting to the NSLDS is done on a timely ...

Views of Responsible Officials and Planned Corrective Actions: Management agrees with the auditors and has initiated the necessary corrective action plan to mitigate the deficiency from occurring again. The plan is to implement new procedures to ensure the reporting to the NSLDS is done on a timely basis. Implementation date: Immediately. Persons Responsible: Vice President of Business & Finance, the Registrars Office and the Director of Student Financial Aid.

View Audit 301315

Finding 390551 (2023-001)

Material Weakness 2023

Michigan Barber School

MI

Student Financial Aid

FINDING 2023-1- Missing Return-to-Title IV (R2T4) Calculations

View Audit 301309

Finding 390551 (2023-001)

Material Weakness 2023

Michigan Barber School

MI

Student Financial Aid

The Institute was unable to locate Return-to-Title IV calculations for six (6) students who withdrew during the audit period.

View Audit 301309

Finding 390551 (2023-001)

Material Weakness 2023

Michigan Barber School

MI

Student Financial Aid

A. Comments on Findings and Recommendations:

View Audit 301309

Finding 390551 (2023-001)

Material Weakness 2023

Michigan Barber School

MI

Student Financial Aid

The Institute agrees with the finding and Auditor’s recommendation.

View Audit 301309

Finding 390551 (2023-001)

Material Weakness 2023

Michigan Barber School

MI

Student Financial Aid

B. Actions Taken or Planned

View Audit 301309

Finding 390551 (2023-001)

Material Weakness 2023

Michigan Barber School

MI

Student Financial Aid

The Institute will re-perform the R2T4 calculations and determine if there were any refunds due back to the Pell Grant Program. Further, the Institute will perform a full-file review of all students withdrawing during the year ended June 30, 2023 to ensure the R2T4 calculation was performed and the ...

The Institute will re-perform the R2T4 calculations and determine if there were any refunds due back to the Pell Grant Program. Further, the Institute will perform a full-file review of all students withdrawing during the year ended June 30, 2023 to ensure the R2T4 calculation was performed and the refunds to the Pell Grant program were accurate.

View Audit 301309

Corrective Action Plans

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