Corrective Action Plans

Finding 521110 (2024-001)

Material Weakness 2024

IL

Questioned Costs Student Financial Aid Cash Management

CORRECTIVE ACTION PLAN Finding No. 2024-001: Credit Card was not reconciled and receipts were not obtained. Expenses were not properly recorded in the general ledger. Recommendation: Management should reconcile credit card accounts monthly and secure receipts for purchases and expenses should be pos...

CORRECTIVE ACTION PLAN Finding No. 2024-001: Credit Card was not reconciled and receipts were not obtained. Expenses were not properly recorded in the general ledger. Recommendation: Management should reconcile credit card accounts monthly and secure receipts for purchases and expenses should be posted to the proper general ledger account. Action Taken or Planned: Credit card accounts will be reconciled and receipts will be requested for purchases. Accounting will review the nature of purchases and properly post to the general ledger. Responsible Person: Mary Amador, Property Manager Completion Date: October 31, 2024

View Audit 341047 Questioned Costs: $1

Finding 521069 (2024-001)

Material Weakness 2024

Northwestern Michigan College

MI

Student Financial Aid Subrecipient Monitoring Material Weakness

Condition: The College did not send out the post-disbursement email notifications to a group of students. Planned Corrective Action: While the College has documented procedures in place for the disbursement of federal funds and required post-disbursement notifications to students, the College did no...

Condition: The College did not send out the post-disbursement email notifications to a group of students. Planned Corrective Action: While the College has documented procedures in place for the disbursement of federal funds and required post-disbursement notifications to students, the College did not properly send a post-disbursement notification to 591 out of 659 students who received federal financial aid loans in Fall 2023. The College will adjust its internal processes to ensure all students who receive federal loans are sent post-disbursement email notifications by performing a weekly review of the report that generates a names list of students that are receiving federal loans. If names exist on the report, a verification in the student record will be conducted to be sure the email was sent. After further investigation, all 608 students that received federal loans in spring semester 2024 and all 56 students in summer of 2024 received a post-disbursement notification. Contact person responsible for corrective action: Lisa Eiden, Director of Student Financial Services Anticipated Completion Date: Immediately

View Audit 340980

Finding 521061 (2024-002)

Significant Deficiency 2024

Watertown School District No. 14-4

SD

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

Finding 2024-002 Federal Agency Name: Department of Education Assistance Listing Number: #84.268 Program Name: Federal Direct Student Loans Finding Summary: 1 of the 60 students selected for testing the reporting of student status changes were reported with the incorrect enrollment status based on N...

Finding 2024-002 Federal Agency Name: Department of Education Assistance Listing Number: #84.268 Program Name: Federal Direct Student Loans Finding Summary: 1 of the 60 students selected for testing the reporting of student status changes were reported with the incorrect enrollment status based on NSLDS Enrollment Reporting guidance. 3 of the 60 students selected for testing the reporting of student status changes were reported to NSLDS with incorrect program begin dates based on NSLDS Enrollment Reporting guidance. 1 of the 60 students selected for testing the reporting of student status changes were reported to NSLDS with an incorrect status effective date based on NSLDS Enrollment Reporting guidance. Corrective Action Plan: LATC currently runs a SQL database script against the enrollment file before sending it to NSC. This script checks for missing and erroneous data (race/ethnicity, nondegree seeking majors, anticipated grad dates, etc.) in the file and updates it to correct values. The Director of Enrollment will work with the Database Administrator to regularly update these tables and review to ensure accurate information is being imported. The Registrar’s office will manually investigate these records and (if necessary) updated before sending the file to NSC. Every 30 days, representatives from the Financial Aid and the Registrar’s departments will pull 10 randomly selected student files to compare information in National Student Clearinghouse, PowerFaids, and NSLDS. The Director of Enrollment will work the error reports that the National Student Clearinghouse sends to LATC after every enrollment file upload with the assistance of the Database Administrator to ensure data submitted is compliant with DOE regulations. The Director of Financial Aid will review NSLDS to ensure corrections submitted by the Director of Enrollment are being properly recorded. Responsible Individual(s): Eric Schultz, Director of Enrollment and Kayla Bossly, Director of Financial Aid Anticipated Completion Date: Corrections complete by December 31, 2024. New process is ongoing.

View Audit 340969

Finding 520916 (2024-003)

Significant Deficiency 2024

Wheeling Jesuit University INC

WV

Student Financial Aid Special Tests & Provisions Reporting

Name of Responsible Individual: Shelia Yates-Mattingly, Registrar Corrective Action: In response to Finding 2024-003, Wheeling University will continue the enrollment reporting process that was implemented in October 2023, which was in response to Finding 2022-005 and continued with the Finding 2...

Name of Responsible Individual: Shelia Yates-Mattingly, Registrar Corrective Action: In response to Finding 2024-003, Wheeling University will continue the enrollment reporting process that was implemented in October 2023, which was in response to Finding 2022-005 and continued with the Finding 2023-005. With the stability of staffing in the Registrar’s Office and Financial Aid Office and the level of experience and competence of this staff, enrollment reporting has been completed within the parameters of regulatory guidelines. The Registrar’s Office submits enrollment reports as scheduled and subsequent error resolution reports as appropriate. The Financial Aid Office reviews identified NSLDS errors, corrects and resubmits them timely. Regularly scheduled meetings, including the Registrar’s and Financial Aid Offices, continue as noted in corrective actions for Findings 2022-005 and 2023-005. These meetings serve as the platform to discuss and address identified enrollment reporting concerns/issues timely, resulting in improved accuracy in enrollment reporting and timeliness in error resolution. In addition, attendance through Census will be monitored in an effort better identify registered but not enrolled students for administrative action and timely reporting. Institutional enrollment reports will be used to identify students who have chosen not to continue their studies at the University but without withdrawing from the institution to alert departments to execute their operational protocols for students who have discontinued enrollment. Students who officially withdraw pursuant to established University protocols will be required to consult with Financial Aid during this process. University departments will continue to be informed of student withdrawals as they occur to inform their practices. Anticipated Completion Date: Processes in place since October 2023 continue and new measures implemented January 2025

View Audit 340797

Finding 520914 (2024-008)

Significant Deficiency 2024

Wheeling Jesuit University INC

WV

Student Financial Aid Internal Control / Segregation of Duties Reporting

Name of Responsible Individual: Tyler Hosey, Senior Accountant & Dylan J. Nowakowski, Director of Financial Aid Corrective Action: Wheeling University acknowledges that we were not in compliance with the 15-day reporting window for a couple of the students in question. This is due to the fact tha...

Name of Responsible Individual: Tyler Hosey, Senior Accountant & Dylan J. Nowakowski, Director of Financial Aid Corrective Action: Wheeling University acknowledges that we were not in compliance with the 15-day reporting window for a couple of the students in question. This is due to the fact that the University is on HCM1 and has to do refunds prior to the export to COD. We know this is a finding for multiple departments and internal controls. With that, there was a delay on these two students that were outside the 15-day window. We now have a policy and procedure in place for the HCM1 work flow. Also, have new staff in place to regulate this, so that we always are following the regulations and staying compliant. The procedure is to make sure we do not have this finding again and stay in compliance with the Department of Education reporting requirement regulation. Anticipated Completion Date: September 2024

View Audit 340797

Finding 520912 (2024-004)

Significant Deficiency 2024

Wheeling Jesuit University INC

WV

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

Name of Responsible Individual: Tracy Jenkins, Student Account Billing Coordinator Corrective Action: We recognized that students were not receiving the Right to Cancel notifications in a timely manner. We also understood the need for students to receive this information to make an important educ...

Name of Responsible Individual: Tracy Jenkins, Student Account Billing Coordinator Corrective Action: We recognized that students were not receiving the Right to Cancel notifications in a timely manner. We also understood the need for students to receive this information to make an important educational/fiscal decision. As of September 2023, on a monthly basis, notifications were sent to student University emails and parent’s personal email (Plus Loan recipients) informing them of their Right to Cancel. Anticipated Completion Date: September 2023

View Audit 340797

Finding 520911 (2024-002)

Significant Deficiency 2024

Wheeling Jesuit University INC

WV

Cash Management Student Financial Aid Internal Control / Segregation of Duties

Name of Responsible Individual: Tyler Hosey, Senior Accountant Corrective Action: The University has formalized and documented financial processes to establish internal controls in order to ensure accurate, timely and consistent reporting. In addition, this has created a reasonable transition pla...

Name of Responsible Individual: Tyler Hosey, Senior Accountant Corrective Action: The University has formalized and documented financial processes to establish internal controls in order to ensure accurate, timely and consistent reporting. In addition, this has created a reasonable transition plan during employee turnover, as well as ensures proper and timely filings. The corrective action involves drawing down the funds from the G5 federal website and issuing refunds to students that day. There is a checks and balance process built in so multiple staff members are involved with the process. The financial aid department calculates the amount of a federal drawdown and relays that information to the business department. The senior accountant draws down the appropriate amount of federal financial aid. The student accounts billing coordinator applies the aid to the various student accounts in the software. After the aid has been applied, the student accounts billing coordinator determines if a refund is due to the students. Any students that are entitled to a refund will be cut a refund check that day. The students will then have a window of opportunity of to come pick up the refund checks. Within two business days, any students who have not picked up their refund checks will have them mailed to their address on file with the University. This process has been developed to ensure that students receive their refunds in a timely and accurate manner. Anticipated Completion Date: February 2024

View Audit 340797

Finding 520909 (2024-009)

Significant Deficiency 2024

Wheeling Jesuit University INC

WV

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

FINDING 2024-009 Name of Responsible Individual: Tracy Jenkins, Student Account Billing Coordinator Corrective Action: Wheeling University worked with ECSI regarding Perkins information. With the Perkins program ending, we realized that we needed to move in the direction of closing out Perkins ...

FINDING 2024-009 Name of Responsible Individual: Tracy Jenkins, Student Account Billing Coordinator Corrective Action: Wheeling University worked with ECSI regarding Perkins information. With the Perkins program ending, we realized that we needed to move in the direction of closing out Perkins files/information. The University is currently working with ECSI so that we are able to submit Perkins information/files to the Department of Education. We are gathering information (promissory notes, bankruptcy details, payment information, etc.) to assist ECSI with the process. Anticipated Completion Date: June 2025

View Audit 340797

Finding 520907 (2024-007)

Significant Deficiency 2024

Wheeling Jesuit University INC

WV

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

Name of Responsible Individual: Lori Kestner, Human Resources Generalist Corrective Action: The payroll Process for Federal Work Study: Student punches in on a computer or cell phone to log in and out when working at the start of their shift and the end of their shift. Timecards can be approved ...

Name of Responsible Individual: Lori Kestner, Human Resources Generalist Corrective Action: The payroll Process for Federal Work Study: Student punches in on a computer or cell phone to log in and out when working at the start of their shift and the end of their shift. Timecards can be approved by their supervisor/manager daily, weekly, or by the pay period which is every two weeks. The pay period ends on a Friday with the payroll processing to begin on the following Monday. On that Monday, all timecards must be corrected/updated and approved before they can be processed. Timecards with errors cannot be processed. Each Monday the supervisor/manager must log into the student timecard and "approve" the card for the pay period that ended on the past Friday. When the supervisor/manager opens the card on Monday it defaults to the current pay period and not the previous pay period that needs to be approved. The supervisor/manager must select the "previous" pay period in order to approve the card to be processed. In the case of the student in question, the supervisor/manager did not select the correct pay period and therefore approved the future timecard. As the payroll manager, I would have emailed him, the manager, that the card to be processed had not been approved. Upon that, he went back and approved the pay period that was to be processed. The approval on the next pay period that he mistakenly approved should have been removed. It was not. The process for card approvals is to check on the Monday of payroll the cards that are still in need of updates/corrections and approvals. A report is run and shows what cards our still without approval and with errors. The payroll manager communicates to the manager and the student that there are errors on the card and/or it still needs to be approved. Payment for that card cannot be made until errors are corrected and the card is approved. It is the supervisor and manager’s responsibility to ensure timecards are corrected and updated for processing. This error can be resolved with the supervisor/manager accountable for the accuracy of the time cards. Before processing a report, can be run by the payroll manager of the date/time of approval. All supervisors and managers who are responsible for the approval of timecards will be reeducated on the process and sign off that they understand their role. Those who do not adhere to the process will have additional training. As new supervisors and managers are hired, the process will be part of their on-boarding. Anticipated Completion Date: January 2025

View Audit 340797

Finding 520906 (2024-010)

Significant Deficiency 2024

Wheeling Jesuit University INC

WV

Internal Control / Segregation of Duties Student Financial Aid Reporting

FINDING 2024-010 Name of Responsible Individual: Tyler Hosey, Senior Accountant Corrective Action: The University acknowledges the FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure t...

FINDING 2024-010 Name of Responsible Individual: Tyler Hosey, Senior Accountant Corrective Action: The University acknowledges the FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provided for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future. Anticipated Completion Date: June 2025

View Audit 340797

Finding 520905 (2024-006)

Significant Deficiency 2024

Wheeling Jesuit University INC

WV

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

Name of Responsible Individual: Tracy Jenkins, Student Account Billing Coordinator Corrective Action: The University acknowledges that we were not in compliance during fiscal year 2024 with the federal guidelines to refund the student credit balances in a timely manner for the students in questio...

Name of Responsible Individual: Tracy Jenkins, Student Account Billing Coordinator Corrective Action: The University acknowledges that we were not in compliance during fiscal year 2024 with the federal guidelines to refund the student credit balances in a timely manner for the students in question. There was significant employee turnover at the University in the business office during fiscal year 2024 and training of new employees was ongoing at that time. This resulted in the delay in the student refunds within the sample selection that the auditors chose during fiscal year 2024. Since then the new and current staff members have been fully trained on their duties and responsibilities. Everyone involved has been informed of the student refund policies and requirements per the Title IV regulations. There have been procedures implemented to prevent this from being a repeat audit finding in the future. Anticipated Completion Date: July 2024

View Audit 340797

Finding 520904 (2024-005)

Significant Deficiency 2024

Wheeling Jesuit University INC

WV

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

Name of Responsible Individual: Dylan J. Nowakowski, Director of Financial Aid Corrective Action: After Colleague was properly set up for Financial Aid for R2T4’s, the Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with...

Name of Responsible Individual: Dylan J. Nowakowski, Director of Financial Aid Corrective Action: After Colleague was properly set up for Financial Aid for R2T4’s, the Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of five days or more, then the R2T4 would have been accurate. The calendar in Colleague has now been corrected. For the years moving forward this will be verified before any R2T4 is calculated and submitted. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break. Anticipated Completion Date: July 2024

View Audit 340797 Questioned Costs: $1

Finding 520894 (2024-001)

Significant Deficiency 2024

Bryant University

RI

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

The University has taken the following steps to improve the accuracy and timeliness of enrollment reporting with respect to federal requirements. Summer withdrawals will now be reported directly to the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its ...

The University has taken the following steps to improve the accuracy and timeliness of enrollment reporting with respect to federal requirements. Summer withdrawals will now be reported directly to the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its enrollment reporting changes to the NSLDS at the time of withdrawal, ensuring timely and accurate reporting. The Registrar’s Office will submit a manual enrollment status change to the Clearinghouse. Since this audit finding was identified in the fall of 2024, the University had already reported all summer 2024 withdrawals during the first fall roster submission.

View Audit 340765

Finding 520857 (2024-002)

None 2024

Williams College

MA

Student Financial Aid Reporting Eligibility

Management agrees with the finding and in concurrence with the recommendations the Registrar’s Office processes and documentation will be updated as follows: Major change process: If a request is submitted to drop a major while a student is on leave, the effective date will be recorded as the date...

Management agrees with the finding and in concurrence with the recommendations the Registrar’s Office processes and documentation will be updated as follows: Major change process: If a request is submitted to drop a major while a student is on leave, the effective date will be recorded as the date of the leave rather than the date the change was initiated. Leave of absence process: All withdrawals will be reported to the National Student Clearinghouse (NSC) manually within 2 weeks of being processed to avoid any delays or issues with the regularly scheduled Peoplesoft delivered report. If due to the schedule, a W status is reported via the delivered report instead of by hand, the person responsible for enrollment reporting will verify the status with the NSC, including program-level data. Ongoing training will be provided and a senior member of our staff will audit the major change and leave of absence processes moving forward. This corrective action plan has been implemented as of January 2025.

View Audit 340686

Finding 520854 (2024-001)

None 2024

Williams College

MA

Student Financial Aid Reporting

Management agrees with the finding and in concurrence with the recommendations we have reviewed the federal verification definitions, and the importance of selecting the correct verification status in the COD system, with staff who participate in the federal verification process to ensure they under...

Management agrees with the finding and in concurrence with the recommendations we have reviewed the federal verification definitions, and the importance of selecting the correct verification status in the COD system, with staff who participate in the federal verification process to ensure they understand the federal definition of number of family members in college. Ongoing training will be provided and a senior member of our staff will audit the verification process moving forward. This corrective action plan has been implemented as of January 2025.

View Audit 340686

Finding 520845 (2024-002)

None 2024

Simpson University

CO

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Our records indicate that the student's account at Simpson University was reported to the National Student Clearinghouse (NSC) on several occasions while the student was enrolled. It is the duty o...

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Our records indicate that the student's account at Simpson University was reported to the National Student Clearinghouse (NSC) on several occasions while the student was enrolled. It is the duty of the NSC program to ensure the accurate transmission of information to the National Student Loan Data System (NSLDS). Once the data leaves Simpson University, the university does not track its progress to other entities. It is recommended that any necessary adjustments be discussed directly with the NSC, particularly if issues arise from their data transfer to third parties. To ensure accuracy, various methods can be implemented, such as conducting random data audits to verify that the information sent to NSC matches that in the NSLDS. This process can be quite exhaustive. Alternatively, a sample audit might involve reviewing a certain error threshold; for instance, if 300 records are submitted, a check of 15-30 records could be performed, reflecting an error tolerance of approximately 5-10%. Another option is for the reporting body to collaborate with NSC in identifying any errors or complications that may affect the correct data transmission. Simpson University maintains evidence that all data submissions to the NSC have been properly reported, accepted, and timely without any discrepancies. Person Responsible for Corrective Action Plan: Adrienne Currington, Registrar Anticipated Date of Completion: Next NSC reporting cycle

View Audit 340662

Finding 520842 (2024-001)

Material Weakness 2024

Simpson University

CO

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

Incorrect and Untimely Returns of Title IV Funds (R2T4) Calculations Planned Corrective Action: The University agrees with these findings. It was determined that these issues primarily resulted from a critical staff shortage in the Financial Aid Office during the audit period. This shortage signific...

Incorrect and Untimely Returns of Title IV Funds (R2T4) Calculations Planned Corrective Action: The University agrees with these findings. It was determined that these issues primarily resulted from a critical staff shortage in the Financial Aid Office during the audit period. This shortage significantly impacted our ability to complete R2T4 calculations accurately and withing the required timeframe. To address these findings, the institution will prioritize the recruitment and onboarding of additional qualified staff to alleviate workload challenges and support timely processing of R2T4s. Concurrently, we will provide comprehensive training to all financial aid staff, focusing on federal regulations, calculation methods, and deadlines. To reduce errors, we will establish a robust quality assurance process that includes a secondary review of all R2T4 calculations before finalization. Person Responsible for Corrective Action Plan: Shondra Dickson, Director of Financial Aid Anticipated Date of Completion: September 1, 2025

View Audit 340662

Finding 520757 (2024-001)

None 2024

State Technical College of Missouri

MO

Student Financial Aid Eligibility Internal Control / Segregation of Duties

2024-001 Incorrect Pell Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2024 Condition Found During our student file testing we noted two students out of forty were not disbursed the correct Pell Grant a...

2024-001 Incorrect Pell Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2024 Condition Found During our student file testing we noted two students out of forty were not disbursed the correct Pell Grant award. Based on the student’s enrollment status and need, the College under awarded the students by $716. We consider this to be an instance of noncompliance relating to the Eligibility Compliance Requirement. Corrective Action Plan The Financial Aid Office will implement a more comprehensive process to review schedule and FAFSA change reports to identify any impact on Pell awards for affected students. Responsible Person for Corrective Action Plan Heather Kleekamp, Director of Financial Aid Implementation Date of Corrective Action Plan January 2, 2025

View Audit 340518

Finding 520704 (2024-001)

Significant Deficiency 2024

San Joaquin College of Law

CA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Financial aid will use an exception report created by IT to identify all currently enrolled students who are not included in the NSLDS Enrollment Report received every 60 days. Financial aid will use this exception report to verify all enrolled students who have current or previous loans are reporte...

Financial aid will use an exception report created by IT to identify all currently enrolled students who are not included in the NSLDS Enrollment Report received every 60 days. Financial aid will use this exception report to verify all enrolled students who have current or previous loans are reported correctly to NSLDS. The Financial Aid Dept will add a task to the August financial aid calendar to manually add/update all incoming 1L students' enrollment in NSLDS who have a current loan originated or showing previous loans in NSLDS. Financial Aid department will use the Enrolled Student Report for the fall semester from the student information system, Sonis, along with the actual disbursement report from Dept of Education's software, EDExpress, to identify students whose enrollment needs to be updated with NSLDS.

View Audit 340442

Finding 520624 (2024-001)

Material Weakness 2024

Milwaukee Institute of Art and Design, Inc.

WI

Reporting Special Tests & Provisions Student Financial Aid

2024-001 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster. Finding Type: Noncompliance and material weakness in internal control over compliance relating to special tes...

2024-001 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster. Finding Type: Noncompliance and material weakness in internal control over compliance relating to special tests. Criteria: The Institute is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately and timely reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that DOE considers high risk. Statement of Condition: Management implemented controls that specifically addressed the some of the circumstances surrounding prior year finding 2023-001. Management's review of the enrollment reporting did not detect errors on certain student Program-Level data elements or timely reporting. Certain student records within the NSLDS were identified with inaccurate Program-Level data elements and not timely reported. Questioned Costs: There were no questioned costs. Context: 9 students were identified with inaccurate Program-Level data elements and not timely reported out of a total of 27 student statuses tested. The Campus-Level data elements were accurately and timely reported. Cause: The Institute’s internal control over compliance did not detect and correct the errors. The preparer incorrectly reported graduate file impacting the student's effective dates and statuses during submission process to NSLDS resulting in inaccuracies in significant Program-Level enrollment data elements that ED considers high risk. The Institute’s internal control over compliance did not detect and correct the error. Effect: The Institute incorrectly reported certain Program-Level records in NSLDS which is information that DOE considers high risk and the Institute’s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of Program-Level data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Management’s Response: Management agrees with the finding. Through internal investigation, it was determined that the date field issues found in 2023 also impacted “special” files, which include graduate data files and are processed differently in-house. This error has been fixed so that both fields will always be the same and accurate using the same method as the 2023-001 finding. The registrar will now confirm both the student-level and program-level data fields upon submission to NSC. Status: Completed January 2024 Contact: Mark Fetherston Vice President for Enrollment Management 414-847-3215 markfetherston@miad.edu

View Audit 340289

Finding 520572 (2024-001)

None 2024

College of the Atlantic

ME

Student Financial Aid

The College has promptly engaged with Federal Student Aid regarding proper corrective actions. The Financial Aid Office has conducted a review of disbursement policies and procedures to prevent future occurrences.

View Audit 340144

Finding 520312 (2024-003)

Significant Deficiency 2024

Chaffey Community College District

CA

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

The Financial Aid department will continue to review and update the reporting procedures. The Director of Financial Aid will review the origination and posting of loans with staff and train them to ensure that dates are consistent and in compliance with Title IV regulations.

View Audit 340029

Finding 520305 (2024-002)

Significant Deficiency 2024

Chaffey Community College District

CA

Student Financial Aid Reporting Significant Deficiency

The departments involved in the enrollment reporting process are continuing to review and enhance the workflow in order to report accurately. Monthly submissions by Information Technology Systems (ITS) will be completed in a timely manner to allow for prompt communication of corrections that are req...

The departments involved in the enrollment reporting process are continuing to review and enhance the workflow in order to report accurately. Monthly submissions by Information Technology Systems (ITS) will be completed in a timely manner to allow for prompt communication of corrections that are required, which are communicated to Admissions and Records by the National Student Clearinghouse (NSCH). Admissions and Records will ensure that error reports provided by NSCH are returned to NSCH within 10 business days to allow for a timely submission to the National Student Loan Database (NSLDS). Staff in Admissions and Records has been specifically assigned to complete error reports to contribute to a prompt submission. The Admissions and Records department will collaborate and communicate with the Financial Aid department to identify students with error codes in NSLDS in an effort to correct them. The Admissions and Records and Financial Aid departments will work with the Internal Auditor to perform semiannual reviews of NSLDS data to ensure accuracy of student records.

View Audit 340029

Finding 520298 (2024-001)

Significant Deficiency 2024

Chaffey Community College District

CA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

The District and its Financial Aid department will continue to review and enhance the workflow and procedures of Return to Title IV. The goal of these efforts has been to meet the compliance requirements of Return to Title IV. The District has developed a schedule with specific dates per term for wh...

The District and its Financial Aid department will continue to review and enhance the workflow and procedures of Return to Title IV. The goal of these efforts has been to meet the compliance requirements of Return to Title IV. The District has developed a schedule with specific dates per term for when calculations will be completed, when requests will be made to Accounting to return the District portion of funds within 45 days, and provide ample timelines that can ensure funds get returned within compliance. The District has included the various department areas and staff that are involved in the process to ensure the schedule is consistent and that the funds are returned in the appropriate time frame. The Financial Aid department will continue to meliorate the task of the Return to Title IV calculations. This task is a work function of the Financial Aid Coordinator position. While staff has been trained to perform this function, the District is currently in recruitment to fill the Financial Aid Coordinator position. While the Coordinator will be expected to perform the calculations, they will be submitted to the Director of Financial Aid for review and to ensure accuracy.

View Audit 340029

Finding 520287 (2024-001)

Significant Deficiency 2024

Calvin University

MI

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

Condition: The University does not have controls in place for review of Return of Title IV calculation. Planned Corrective Action: All R2T4 calculations will be reviewed by a second individual within the Calvin Financial Aid Office. Calculations will not become final until both individuals agree wit...

Condition: The University does not have controls in place for review of Return of Title IV calculation. Planned Corrective Action: All R2T4 calculations will be reviewed by a second individual within the Calvin Financial Aid Office. Calculations will not become final until both individuals agree with the specifics of each calculation. Contact person responsible for corrective action: James Koeman, Director of Financial Aid Anticipated Completion Date: Already completed as of the 24FA term.

View Audit 340021

Corrective Action Plans

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