Corrective Action Plans

Condition The Federal Supplemental Educational Opportunity Grants and Federal Work Study Program sections of the FISAP (Part VI), contained several inputs that could not be reconciled to underlying supporting documentation. Corrective Action Plan Corrective Action Planned: The newly hired Director o...

Condition The Federal Supplemental Educational Opportunity Grants and Federal Work Study Program sections of the FISAP (Part VI), contained several inputs that could not be reconciled to underlying supporting documentation. Corrective Action Plan Corrective Action Planned: The newly hired Director of Financial Aid will be required to retain all data and reports related to the FISAP report which relates to the audit. The Director has been cross training the necessary Financial Aid Office Staff in process of obtaining and retaining all data related to the FISAP. The Director has taken the time to refer to previous reports, notes, and instructions in completing the 2023 FISAP. The sections in question have been completed correctly and have similar reporting to prior years. Name(s) of Contact Person(s) Responsible for Corrective Action: Tom Kendziora, Director of Financial Aid Anticipated Completion Date: September 30, 2023

View Audit 301276

Finding 390465 (2023-003)

Significant Deficiency 2023

Adrian College

MI

Student Financial Aid Significant Deficiency

Condition: Certain credit balances were not refunded to students within the required fourteen (14) days. Context - Of the 25 students tested, there was 1 student who had credit balances created by Title IV funds that were not refunded within 14 days. Planned Corrective Action: The Manager of Student...

Condition: Certain credit balances were not refunded to students within the required fourteen (14) days. Context - Of the 25 students tested, there was 1 student who had credit balances created by Title IV funds that were not refunded within 14 days. Planned Corrective Action: The Manager of Student Business Services, working with the Director of Financial Aid, will identify to the Vice-President of Business Affairs (VPBA) those students who are scheduled to receive special supplemental institutional aid (refer to Note below) and identify if that supplemental aid amount will place the student in a credit balance. The VPBA will then determine if the supplemental aid amount should be adjusted. If there is no adjustment, any credit balance will be processed for refund within the required fourteen (14) day period. Note: This finding relates to a certain classification of students who receive supplemental intuitional aid in the form of a special scholarship (“The Godard Scholarship”). The intent of the scholarship was to supplement other forms of financial aid available to students such that the student’s account balance would equal zero. The scholarship amount was not adjusted from that originally communicated to students resulting in some students having a credit balance on their account. Rather than reducing the scholarship amount, the administration elected to honor that amount initially communicated to the scholarship recipients. The timing of this decision contributed to refund payments being delayed beyond the allowable period for this certain classification of students. There were no questioned costs associated with the finding. Contact person responsible for corrective action: Jerry Wright VP Business Affairs/CFO Anticipated Completion Date: Academic Year 2023-2024

View Audit 301249

Finding 390464 (2023-002)

None 2023

Adrian College

MI

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Condition: The College did not report certain students’ status to the National Student Loan Data System (NSLDS) in an accurate and timely manner during the fiscal year. Context - There were two errors identified that attributed to this finding: 1) Of the 40 students tested, there were 10 students w...

Condition: The College did not report certain students’ status to the National Student Loan Data System (NSLDS) in an accurate and timely manner during the fiscal year. Context - There were two errors identified that attributed to this finding: 1) Of the 40 students tested, there were 10 students who withdrew or graduated whose status changes were not reported accurately to the NSLDS. The students were reported timely but with an incorrect effective date. 2) Of the 40 students tested, there were 33 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. Planned Corrective Action: The College corrective action plan implemented as of the time of this communication has included integrated feedback from multiple campus constituencies received through a series of meetings led by our Academic Dean in order to define a process focused on managing this particular compliance obligation. The participating departments included; Academic Affairs, Enrollment, Financial Aid, Business Office, IT, Registrar, Student Life, Academic Services and the President’s Office. The result was development of an internal policy with clearly defined protocols, procedures and timelines (referred to as the “Adrian College Data Integrity Notification Guidelines” policy document). Assessment will be periodically evaluated via the College’s internal audit process. Note: • Re status change for withdrawn or graduating students: The College submitted its report to the National Student Clearinghouse (NSC) twenty-eight (28) days prior to the sixty (60) day requirement to be received by the NSLDS. The College was subsequently notified by NSC that it had been the victim of a third-party security breach. We believe this event contributed to delay for the NSC to review, certify and post to the NSLDS; contributing to this finding. Re student reporting with incorrect effective dates posted: It appears that the effective dates submitted by the College to NSC were subsequently modified within the NSC database. We believe a third-party security breach identified to the College by NSC may have contributed to the posting of incorrect effective dates to NSLDS; contributing to this finding. There were no questioned costs associated with the finding. Contact person responsible for corrective action: Andrea Milner VP Academic Affairs/Dean Anticipated Completion Date: Academic Year 2023-2024

View Audit 301249

Finding 390445 (2023-004)

Significant Deficiency 2023

Oregon Tech

OR

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend that they assign the loans back to the Department of Education or have the students resign the loans via Electronic MPN or Paper MPN and retain those in the proper manner. Explanation of disagreement ...

Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend that they assign the loans back to the Department of Education or have the students resign the loans via Electronic MPN or Paper MPN and retain those in the proper manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management respectfully agrees on all findings and recommendations. Management will engage in additional staff training and is committed to consistent application of current policies and procedures to ensure all student loan documentation is maintained per the U.S. Department of Education policies. Management will assign the respective loans back to the Department of Education as to be in compliance with U.S. Department of Education requirements. Name(s) of the contact person(s) responsible for corrective action: Karissa Sultan Planned completion date for corrective action plan: June 30, 2024

View Audit 301235

Finding 390438 (2023-001)

Significant Deficiency 2023

Oregon Tech

OR

Student Financial Aid Subrecipient Monitoring Reporting § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting i...

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management respectfully agrees on all findings and recommendations. Management will engage in additional staff training and is committed to consistent application of current policies and procedures to ensure enrollment reporting and monitoring of third-party service providers results in accurate and timely reporting by the third-party service provider. While the third-party service provider has a national monopoly on enrollment reporting, with other institutions of higher education also facing similar reporting issues by the third-party service provider, Management believes that enhanced training and internal procedures over enrollment reporting will mitigate accuracy and timeliness errors made by the third party service provider, resulting in the University meeting U.S. Department of Education requirements. Name(s) of the contact person(s) responsible for corrective action: Ashlie Pence Planned completion date for corrective action plan: June 30, 2024

View Audit 301235

Finding 390420 (2023-005)

Material Weakness 2023

Delaware State University

DE

Matching / Level of Effort / Earmarking Student Financial Aid Material Weakness § 200.303

2023-005 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally...

2023-005 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar’s Office will strengthen procedures and reporting practices to ensure timely submission to the National Student Clearinghouse (NSCL) & the National Student Load Data System (NSLDS). The Registrar’s Office will confirm and ensure the submissions to the National Student Clearinghouse (NSCL) corresponds with the timeframe the enrollment is rolled over to the National Student Loan Data System (NSLDS). Name(s) of the contact person(s) responsible for corrective action: Registrar, Dr. Genita Mangum Planned completion date for corrective action plan: July 2024

View Audit 301226

Finding 390410 (2023-002)

Significant Deficiency 2023

Metropolitan Community College Area

NE

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster Recommendation: We recommend the College reviews their policies to ensure all requirements from the Department of Education are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to findi...

Student Financial Assistance Cluster Recommendation: We recommend the College reviews their policies to ensure all requirements from the Department of Education are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MCC SAP policy has been corrected and updated to meet federal requirements on calculating the pace a student must progress through their educational program. Moving forward Financial Aid Management will review their policies and procedures annually to ensure that we are meeting all Department of Education SAP requirements. Name(s) of the contact person(s) responsible for corrective action: Kelsey Scott Planned completion date for corrective action plan: Spring 2024

View Audit 301214

Finding 390401 (2023-002)

Significant Deficiency 2023

Livingstone College

NC

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

Finding 2023-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Deficiency): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs a) One (1) out of six (6) stu...

Finding 2023-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Deficiency): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs a) One (1) out of six (6) students tested for R2T4 did not have Title IV funds returned to the Federal government within the required 45 days. Title IV HEA 34 CFR 668.22. b) The College was not reconciling between Financial Aid and Business Office on the monthly basis per SFA Handbook Ch. 5 CFR668.161-668.176. Auditor’s Recommendation – We recommend that the College ensure adequate documentation is obtained and kept on file as evidence that all expenditures meet allowable cost and other requirements under the grant program. Corrective Action – Management agrees with this finding. The College will place additional emphasis on the R2T4 of funds. Management is reviewing the timing of presentation of situations to Financial Aid that require returning funds to the Department. Additional focus will be placed on procedures to timely report withdraws to Financial Aid to support returned funds in the required 45 days. In addition, the College prepares monthly reconciliations between Financial Aid and the Business Office, but often delayed in completion. Going forward, the reconciliation will be noted on the monthly closing list and requires both the Assistant Vice President of Financial Aid and Controller to sign and date the reconciliation to demonstrate compliance with the monthly requirement.

View Audit 301203

Finding 390307 (2023-002)

Significant Deficiency 2023

University of Massachusetts Global-9 Month Audit

CA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

University of Massachusetts Global concurs with this finding. The University utilizes the services of National Student Clearinghouse to report student status data to the NSLDS. There were 6 students reported as graduated beyond the 60 days, and 1 student with an error that was not corrected within 1...

University of Massachusetts Global concurs with this finding. The University utilizes the services of National Student Clearinghouse to report student status data to the NSLDS. There were 6 students reported as graduated beyond the 60 days, and 1 student with an error that was not corrected within 10 days. To address this, the Office of the Registrar now has access to NSLDS to ensure that what is reported to NSC is also updated accurately in NLSDS. The Office of the Registrar will also change the reporting dates so that it best aligns with the conferral dates. In addition, the Office of the Registrar will have an additional QA process so that any time status changes are compared against the NSC report that is generated and submitted.

View Audit 301167

Finding 390306 (2023-001)

Significant Deficiency 2023

University of Massachusetts Global-9 Month Audit

CA

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

University of Massachusetts Global concurs with this finding. To address this, a new control has been added beginning with the 2023-2024 fiscal year. The new step added is for a systems specialist to confirm that the batch process for award notifications has been completed, and that the notification...

University of Massachusetts Global concurs with this finding. To address this, a new control has been added beginning with the 2023-2024 fiscal year. The new step added is for a systems specialist to confirm that the batch process for award notifications has been completed, and that the notifications have been sent to students prior to disbursements of Title IV aid.

View Audit 301167

Finding 390285 (2023-012)

Significant Deficiency 2023

Commonspirit Health

IL

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

REFERENCE: 2023-012 – Special Tests and Provisions – Return of Title IV Funds SFA Cluster (Assistance Listing No. 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science Finding: Good Samaritan College of Nursing and Health Science did no...

REFERENCE: 2023-012 – Special Tests and Provisions – Return of Title IV Funds SFA Cluster (Assistance Listing No. 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science Finding: Good Samaritan College of Nursing and Health Science did not calculate and return Title IV funds in a timely manner to the U.S. Department of Education, within 45 days after the date the institution determined that a student withdrew. Good Samaritan College of Nursing & Health Science did not provide evidence of an effective review process to ensure the timely calculation and return of Title IV funds to the U.S. Department of Education. Corrective Action Plan: To ensure timely returns, Financial Aid Services will incorporate an additional step to the return disbursement process. The additional step will occur after each return to ensure the Common Origination and Disbursement (COD) system shows the return successfully processed for the student. Financial Aid Services will review the student’s disbursement detail history in COD to confirm the return credit adjustment has been applied to the appropriate record and it shows an applied date at ED within the appropriate timeframe for the return. To document this process has been completed, Financial Aid Services will maintain a spreadsheet for all returns. The spreadsheet will document the student, amount of the return, date processed in Financial Aid and Student Accounts, date processed in G5, and date applied at ED per COD. If any issues arise during this review where the return did not successfully apply at ED, Financial Aid Services will review and resolve rejects immediately so the record can move forward and process successfully within the required timeframe. The Dean of Financial Services will validate the report submitted by Financial Aid Services on a monthly basis and submit the document to the President. Both will review and sign the documentation. This documentation will be presented to the GSC Compliance Oversight Committee to ensure monthly verification of time return of Title IV funds. Person Responsible: Judy Kronenberger, President Good Samaritan College of Nursing and Health Science Expected Completion: April 2024

View Audit 301158

Finding 390280 (2023-007)

Material Weakness 2023

Commonspirit Health

IL

Student Financial Aid Matching / Level of Effort / Earmarking Significant Deficiency § 200.303

REFERENCE: 2023-007 – Special Tests and Provisions – Disbursements to or on Behalf of Students SFA Cluster (Assistance Listing No. 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Find...

REFERENCE: 2023-007 – Special Tests and Provisions – Disbursements to or on Behalf of Students SFA Cluster (Assistance Listing No. 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samaritan College of Nursing & Health Science did not send loan notifications to 3 of 30 students selected for disbursement testing for direct loans within 30 days of funds being disbursed. CHI Health School of Radiologic Technology did not send loan notifications to 14 of 14 students for disbursement testing with direct loans within 30 days of funds being disbursed. Corrective Action Plan: This finding has been corrected for Good Samaritan. As of May 2023, for April 2023 loan disbursements, compliance is verified monthly through internal audit of student disbursements. A sample of disbursements is checked for proper and timely notifications. Timeliness of notifications is checked and verified by the Compliance Oversight Committee monthly. CHI Health School of Radiologic Technology will review their processes to develop and implement internal controls that ensure compliance with federal regulations. Evidence of the internal control being performed will be retained. Person Responsible: Judy Kronenberger, President, Good Samaritan College of Nursing and Health Science David Velasquez, Nuclear Medicine Technologist Coordinator CHI Health School of Radiologic Technology Completion/Expected Completion: April 2023 (Good Samaritan)/June 2024 (CHI Health School of Radiologic Technology)

View Audit 301158

Finding 390274 (2023-008)

Significant Deficiency 2023

Commonspirit Health

IL

Special Tests & Provisions Student Financial Aid Eligibility § 200.303

REFERENCE: 2023-008 – Special Tests and Provisions – Satisfactory Academic Progress SFA Cluster (Assistance Listing No. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: CHI Health School of Radiologic Technology Finding: CHI Health School of Radiologic Technology had no docum...

REFERENCE: 2023-008 – Special Tests and Provisions – Satisfactory Academic Progress SFA Cluster (Assistance Listing No. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: CHI Health School of Radiologic Technology Finding: CHI Health School of Radiologic Technology had no documented evidence of review and approval of Satisfactory Academic Policy. Additionally, the Satisfactory Academic Policy did not contain all required elements according to federal regulations. Corrective Action Plan: CHI Health School of Radiologic Technology has revised the Satisfactory Academic Policy to incorporate the required components. Additionally, CHI Health will implement documentation procedures including an agenda and minutes for their annual meeting to review the school policies. Person Responsible: Robert Hughes, Program Director, CHI Health School of Radiologic Technology Expected Completion: June 2024

View Audit 301158

Finding 390273 (2023-006)

Material Weakness 2023

Commonspirit Health

IL

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

REFERENCE: 2023-006 – Reporting – Common Origination and Disbursement (COD) System Student Financial Assistance Cluster (Assistance Listing Nos. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radi...

REFERENCE: 2023-006 – Reporting – Common Origination and Disbursement (COD) System Student Financial Assistance Cluster (Assistance Listing Nos. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samaritan College of Nursing & Health Science did not perform its internal control over the requirement to submit Pell and Direct Loan origination and disbursement records to the Department of Education through the COD system, which consists of monthly COD reconciliations. CHI Health School of Radiologic Technology does not have a process in place for updating the COD system for actual disbursement dates. The COD disbursement information reported by CHI Health School of Radiologic Technology was based on “assumed” and “expected” disbursement dates and amounts, but is never updated for actual disbursement dates. Corrective Action Plan: This finding has been corrected for Good Samaritan. In May 2023, for April 2023 data, Good Samaritan implemented a formal monthly reconciliation process, including comparison of all systems for the period, a final review of G5 funds prior to draw down, a cover sheet noting any explaining any differences, proper sign off for preparation and review and the date by Good Samaritan management for presentation to the Compliance Oversight Committee. A year end reconciliation is also performed following the same process. CHI Health School of Radiologic Technology will review their processes to develop and implement internal controls that ensure compliance with federal regulations. Evidence of the internal control being performed will be retained. Person Responsible: Judy Kronenberger, President Good Samaritan College of Nursing and Health Science and Financial Aid Services (FAS) David Velasquez, Nuclear Medicine Technologist Coordinator (CHI Health School of Radiologic Technology) Completion/Expected Completion: April 2023 (Good Samaritan)/June 2024 (CHI Health School of Radiologic Technology)

View Audit 301158

Finding 390270 (2023-005)

Material Weakness 2023

Commonspirit Health

IL

Student Financial Aid Matching / Level of Effort / Earmarking Cash Management § 200.303

REFERENCE: 2023-005 – Cash Management Student Financial Assistance Cluster (Assistance listing No. 84.007, 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samar...

REFERENCE: 2023-005 – Cash Management Student Financial Assistance Cluster (Assistance listing No. 84.007, 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samaritan College of Nursing & Health Science has processes in place for determining the amount of student financial aid to be drawn down and disbursed; however, management did not perform internal controls over cash management throughout the year. CHI Health School of Radiologic Technology has processes in place for determining the amount of Direct Loans and Pell grants to be drawn down and disbursed; however, there is no review control in place over the disbursement amounts before funds are drawn down from the G5 system. Corrective Action Plan: This finding has been corrected for Good Samaritan. In May of 2023, for April 2023 data, Good Samaritan implemented a formal monthly reconciliation process, including comparison of all systems for the period, a final review of G5 funds prior to draw down, a cover sheet noting any explaining any differences, proper sign off for preparation and review and the date by Good Samaritan management and FAS management. This review is presented monthly to the Compliance Oversight Committee. A year end reconciliation is also performed following the same process. CHI Health School of Radiologic Technology will implement a review control for accounting staff to review the draw down amount provided by the School prior to completing the drawn down. Documentation of the review will be retained. Person Responsible: Judy Kronenberger, President, Good Samaritan College of Nursing and Health Science and Andrea Heffelfinger, Market Director of Accounting (CHI Health) Completion/Expected Completion: April 2023 (Good Samaritan)/June 2024 (CHI Health School of Radiologic Technology)

View Audit 301158

Finding 390261 (2023-102)

Material Weakness 2023

Maricopa County Community College District

AZ

Questioned Costs Eligibility Student Financial Aid § 200.303 § 200.513 § 200.521

Cluster name: TRIO Cluster Assistance Listing number and name: 84.042 TRIO – Student Support Services 84.047 TRIO – Upward Bound Award numbers and years: P047A171009, September 1, 2017 through August 31, 2022 P047A170820, September 1, 2017 through August 31, 2023 P042A200873, P042A201342, and...

Cluster name: TRIO Cluster Assistance Listing number and name: 84.042 TRIO – Student Support Services 84.047 TRIO – Upward Bound Award numbers and years: P047A171009, September 1, 2017 through August 31, 2022 P047A170820, September 1, 2017 through August 31, 2023 P042A200873, P042A201342, and P042A200859, September 1, 2020 through August 31, 2025 P047A221154 and P047A221160, September 1, 2022 through August 31, 2027 Federal Agency: U.S. Department of Education Compliance Requirements: Eligibility Questioned costs: $5,612 Name of contact persons: Kristina Winterstein, Associate Controller, District Business Services Anticipated completion date: June 30, 2024 The District is aware of the importance of maintaining effective internal control over federal awards and ensuring compliance with applicable federal regulations. The District will work with the TRIO project directors at each college to review and revise existing procedures to require an independent and knowledgeable employee review and approve student eligibility determinations prior to awarding program services to them. The District will enhance communication and training efforts to ensure that the TRIO project directors and all staff administering the TRIO programs understand all eligibility requirements and related district-wide policies and procedures. As of March 21, 2024, the questioned costs for the program have been resolved.

View Audit 301142 Questioned Costs: $1

Finding 390255 (2023-101)

Material Weakness 2023

Maricopa County Community College District

AZ

Questioned Costs Student Financial Aid Special Tests & Provisions § 200.303

Cluster Name: Student Financial Assistance Cluster Assistance Listing number and name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program-Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Fed...

Cluster Name: Student Financial Assistance Cluster Assistance Listing number and name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program-Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award Year: July 1, 2021 through June 30, 2022 Federal Agency: U.S. Department of Education Compliance Requirements: Special tests and provisions Questioned Costs: Unknown Name of Contact Persons: Joshua Lindenberg, District Director of Financial Aid Anticipated Completion Date: December 31, 2024 The Maricopa County Community College District understands the importance of reporting accurate student enrollment statuses and all student enrollment status changes to the National Student Loan Database (NSLDS) for the Pell and Direct Loan programs. System improvements were completed in June 2023 to reduce and prevent enrollment reporting errors. The District will continue to enhance internal controls by expanding procedures to proactively monitor, detect, and correct unresolved enrollment reporting errors and will conduct semi-annual quality assurance reviews of student accounts to ensure enrollment data is reported appropriately to the NSLDS. The district will assess and enhance the existing enrollment reporting transmission schedule, documenting and disseminating a final copy to staff to ensure optimal efficiencies and reduce enrollment reporting errors caused by the timing of data transmission and error processing.

View Audit 301142 Questioned Costs: $1

Finding 390235 (2023-002)

Material Weakness 2023

National University

CA

Student Financial Aid Material Weakness Reporting

Finding 2023-002 - Special Tests and Provisions – Enrollment Reporting: Material Weakness in Internal Control Management agrees with this finding. The institution proposes a multifaceted approach aimed at resolving the root causes of the inaccuracies and preventing their recurrence. National Univer...

Finding 2023-002 - Special Tests and Provisions – Enrollment Reporting: Material Weakness in Internal Control Management agrees with this finding. The institution proposes a multifaceted approach aimed at resolving the root causes of the inaccuracies and preventing their recurrence. National University has implemented regular reviews of its enrollment reporting. During this process, errors in reporting are identified and corrected. However, the timing of the review has not allowed enough time to process corrections within compliance. To allow for appropriate adjustments and corrections to be implemented after testing but before the enrollment reporting deadline, National University will shift the timing of its enrollment reporting review from 60 to 30 days. Though NU is currently testing enrollment reporting and adjusting queries in an ongoing effort to improve accuracy, some of those adjustments inadvertently caused students to not appear in our queries. This impact on reporting occurred in edge cases not taken into account in the queries. To ensure this does not happen in the future, NU will implement a testing regime for these queries. This testing will be conducted at regular intervals to verify the effectiveness and accuracy of the queries in identifying students who have ceased attendance as required. Through these concerted efforts, NU hopes to demonstrate its full commitment to addressing the audit findings. We know that these efforts will take time to fully take effect and be reflected in future audits. Contact Person Responsible for Corrective Action: Brandy Baker, Director of Quality Assurance and Sarah Massey, AVP Operations, Student Support and Registrar Anticipated Completion Date: June 2024

View Audit 301132

Finding 390234 (2023-001)

Material Weakness 2023

National University

CA

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

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. Finding 2023-001 - Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University agrees with this finding. As we c...

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. Finding 2023-001 - Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University agrees with this finding. As we continue to refine our R2T4 processes, we’ve had two key challenges we are addressing: Timeliness of R2T4 calculations: In FY22, NU identified an issue with how it was identifying unofficial withdrawals at the institution. To assist in rectifying the issue, we implemented a 35-day attendance policy that resulted in a significant amount of students being attritted from the University. We were working with a third-party firm to help us complete all the R2T4 calculations, which proved challenging; between our internal staffing and external support, we did not have the ability to do all of the calculations timely. As we’ve analyzed the needed manpower, we’ve expanded our Processing and Quality Assurance teams. The establishment of two additional teams within the Processing team in 2024 underscores our commitment to ensuring the timely completion of necessary calculations. Simultaneously, the increased Quality Assurance team is poised to support the enhanced internal controls, conducting weekly reviews of R2T4 calculations to verify their accuracy and timeliness. Missing students for R2T4 calculations who were withdrawn: We have established precise and accurate criteria for the development and execution of report queries. This initiative aims to ensure the comprehensive identification of students who discontinue attendance before the end of a payment period, thereby mitigating the risk of oversight. To bolster the reliability of these refined processes, NU is committed to implementing regular testing of the attendance queries. By conducting these tests at established intervals, the institution seeks to verify that the queries consistently identify the correct cohort of students. This approach serves as a crucial mechanism to maintain the accuracy of our withdrawal determination processes and underscores our dedication to continuous improvement. Through these concerted efforts, NU hopes to demonstrate its full commitment to addressing the audit findings. We know that these efforts will take time to fully take effect and be reflected in future audits. Contact Person Responsible for Corrective Action: Brandy Baker, Director of Quality Assurance Angela De Angelini, AVP Processing and Fiscal Operations Anticipated Completion Date: June 2024

View Audit 301132

Finding 390231 (2023-003)

Significant Deficiency 2023

Rider University

NJ

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

Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform. Explanat...

Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Recognizing the importance of resolving this finding the University intends to adjust policies and procedures around reviewing the third-party servicer processes around regulations and compliance items therein. Name(s) of the contact person(s) responsible for corrective action: Miranda Cole, Director and Tristan Schmittinger, Associate Director. Planned completion date for a corrective action plan: 3/26/2024

View Audit 301124

Finding 390230 (2023-002)

Significant Deficiency 2023

Rider University

NJ

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

Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: CLA recommends the University review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding: T...

Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: CLA recommends the University review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: In addition to the University’s automated procedures, Financial Aid and the Registrar will reconcile the finalized listing of graduates for each semester to confirm that all students are receiving exit counseling requirements and ensure proper counseling is provided to students. Name(s) of the contact person(s) responsible for corrective action: Miranda Cole, Director and Tristan Schmittinger, Associate Director. Planned completion date for a corrective action plan: 3/19/2024

View Audit 301124

Finding 390228 (2023-001)

Significant Deficiency 2023

Rider University

NJ

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Federal Pell Grant Program, Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268. Recommendation: We recommend the University review procedures around sending the correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the ...

Federal Pell Grant Program, Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268. Recommendation: We recommend the University review procedures around sending the correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Registrar's Office can confirm the National Student Clearing House (NSC) enrollment history for all two students is accurate. It appears that there have been challenges with the National Student Loan Data System (NSLDS) receiving current data from NSC in a timely manner. We take action to ensure that we will work with Financial Aid and crossreference the Registrar's monthly submission report and/or weekly Withdrawal Report with an NSLDS' report provided by Financial Aid to address any discrepancies. We will also work with the NSC audit team to ensure if there are any other processes, that we can implement on our end to better oversee the submission with our third-party servicer (NSC). Name(s) of the contact person(s) responsible for corrective action: Justina Nicita, Assistant Registrar, and Miranda Cole, Director of Financial Aid. Planned completion date for a corrective action plan: 3/19/2024.

View Audit 301124

Finding 390202 (2023-003)

None 2023

St. Lukes Health Network, Inc. and Controlled Entities

PA

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

2023-003 -Return of the Title IV R2T4 Calculation Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal ...

2023-003 -Return of the Title IV R2T4 Calculation Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2022-2023 Pass-through entity: Not applicable The Network agrees with the finding, and will make the following enhancement to the process: A review of the R2T4 calculation will be evidenced to ensure the calculation is prepared completely and accurately to determine whether a refund is required as well as to verify any post-withdrawal disbursements. The Network is implementing this process beginning in Q4 of FY2024. For inquiries regarding this finding, please contact Lisa Storck, Senior Associate Dean, and Joe Zelasko, Senior Financial Aid Coordinator, who are responsible for the corrective action.

View Audit 301103

Corrective Action Plans

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