Corrective Action Plans

Finding 526136 (2024-096)

Significant Deficiency 2024

VA

Student Financial Aid Reporting Significant Deficiency

Responsible Contact Person(s): Brad Barnett, Director, University Scholarships and Financial Aid Corrective Action Planned: Implement a "direct loan posting date audit report procedure," which outlines how posting dates in the management application are compared to posting dates in the system. Also ...

Responsible Contact Person(s): Brad Barnett, Director, University Scholarships and Financial Aid Corrective Action Planned: Implement a "direct loan posting date audit report procedure," which outlines how posting dates in the management application are compared to posting dates in the system. Also add a checklist item to the monthly reconciliation to confirm the new procedure is being followed. Estimated Completion Date: 4/1/2025

View Audit 345214

Finding 526135 (2024-095)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Special Tests & Provisions Student Financial Aid Reporting

NVCC Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Corrective Action Planned: Step 1: Additional training was provided to all relevant financial aid staff focusing on the accurate and timely calculation and return of unearned Title IV funds. This training emphasized the ...

NVCC Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Corrective Action Planned: Step 1: Additional training was provided to all relevant financial aid staff focusing on the accurate and timely calculation and return of unearned Title IV funds. This training emphasized the importance of adhering to regulatory guidelines and utilizing the institution's Information System-generated Return to Title IV (R2T4) report. Step 2: Quality control process has been implemented. The Associate Director or Director of Financial Aid will conduct a thorough review and quality control check of all R2T4 calculations prior to the return of funds. Estimated Completion Date: 6/30/2025 ODU Responsible Contact Person(s): Stephanie Jennelle, Associate Vice President for Budget and Financial Planning Corrective Action Planned: The University is taking corrective action to ensure unclaimed aid is promptly returned. Corrective action includes enhancing procedures for processing unclaimed checks containing Title IV funds. These enhancements include modifying the timing and frequency of outreach and follow up due diligence to students to ensure unclaimed Title IV funds are returned timely. Estimated Completion Date: 12/31/2025 RU Responsible Contact Person(s): Allison Pratt, Director of Financial Aid Corrective Action Planned: The accounting, financial aid, and internal audit departments have met to plan corrective actions. As procedure updates were occurring through the fiscal year that was audited, Internal audit initially chose additional sampling periods to test. Procedures are being reviewed and will continue to be updated in accordance with the finding results and Internal Audits' findings. Estimated Completion Date: 6/30/2025

View Audit 345214

Finding 526134 (2024-094)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Student Financial Aid Significant Deficiency Special Tests & Provisions

GMU Responsible Contact Person(s): Alethia Shipman, Director, Student Financial Aid Corrective Action Planned: To ensure guidelines are followed, a comprehensive plan of action will be implemented. This plan includes establishing a formal training structure with annual reviews of key procedures, rev...

GMU Responsible Contact Person(s): Alethia Shipman, Director, Student Financial Aid Corrective Action Planned: To ensure guidelines are followed, a comprehensive plan of action will be implemented. This plan includes establishing a formal training structure with annual reviews of key procedures, revision of in-person inquiries, and an internal quality assurance review that will be conducted on a monthly basis. Estimated Completion Date: 12/31/2025 NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office has taken steps to review all verification updates made to students who have been selected for verification. Once a student has been verified, tracking of that student’s correction will be made. A review of changes made will be conducted to ensure that all changes have been entered correctly into the system and that the correction has been imported correctly prior to releasing the tracking hold onto the account. Also, a sample of students will be randomly selected monthly to ensure students who have been selected for verification or who have an ISIR comment code that needs resolution are reviewed for accuracy. Estimated Completion Date: 8/31/2025 ODU Responsible Contact Person(s): Vera Riddick, Director of Financial Aid Corrective Action Planned: The University is taking corrective action to ensure continued efficiency, accuracy, and adherence to federal regulations. Corrective actions include providing intensive training for new Financial Aid verification team members and annual training for all Financial Aid team members, implementing quality assurance reports, and increasing reviews throughout the verification cycle. The University is also exploring other tools to assist with the verification process. The three test cases identified during the audit have been reviewed and federal funds have been returned as warranted. Estimated Completion Date: 12/31/2025 VPISU/ID Responsible Contact Person(s): Nicci Ratcliff, Associate Director for Processing Operations Corrective Action Planned: VPISU/ID updated the system tracking group logic to ensure verification is requested timely and reviewed all 2023-24 verification files ensuring required documents were on file. The University will include a weekly random sample of files flagged for verification and confirm that documentation is complete prior to disbursement. The University will provide additional annual training and a documentation requirements checklist to improve Specialist completion of the verification process and ensure consistent handling and retention of all required documents. Estimated Completion Date: 7/31/2025

View Audit 345214

Finding 526133 (2024-093)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Student Financial Aid Reporting Significant Deficiency

NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office will ensure that the unearned funds for students will be sent to COD timely. NSU will ensure that all files are submitted timely so that this will not be a future issue....

NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office will ensure that the unearned funds for students will be sent to COD timely. NSU will ensure that all files are submitted timely so that this will not be a future issue. A reinforcement of procedures for exporting disbursements and staff training will be maintained as well as ensuring that a back-up staff member is in place. Estimated Completion Date: 8/31/2025 NVCC Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Linsha Xie, Controller Corrective Action Planned: Step 1: Establish clear and documented communication protocols between the Financial Aid Office and the Controller's Office regarding student withdrawals and the return of unearned Title IV funds. This will include designated points of contact in each office, a standardized process for the Financial Aid Office to notify the Controller's Office of requiring a return of Title IV funds, confirming the return by the Controller’s Office, and regular meetings between the two offices to review procedures and address any issues. Step 2: Develop a written policy and procedure. This will include step-by-step instructions for processing the return of funds, including required documentation and timelines, Clear delineation of responsibilities between the Financial Aid Office and the Controller's Office, and contingency plans for staff turnover or absences. Step 3: Conduct periodic reviews and reconciliation of returned Title IV funds to ensure accuracy and timeliness. This will include reconciling returned funds with ED records and identifying any discrepancies or delays in the return of unearned funds. Estimated Completion Date: 6/30/2025 ODU Responsible Contact Person(s): Vera Riddick, Director of Financial Aid Corrective Action Planned: The University is taking corrective action to improve processes to ensure data accuracy and compliance with reporting requirements. Corrective actions include utilizing system functionality and enhancing Office of Student Financial Aid procedures. Differences totaling $325 that were identified during the audit have been returned to the Department of Education. Estimated Completion Date: 12/31/2025

View Audit 345214

Finding 526132 (2024-092)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Student Financial Aid Special Tests & Provisions Significant Deficiency

NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office has created a Certification Form of Countable Days in a Semester that is required to be signed off by the Director of Financial Aid, Associate Director of Financial Aid (...

NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office has created a Certification Form of Countable Days in a Semester that is required to be signed off by the Director of Financial Aid, Associate Director of Financial Aid (Return of TIV Coordinator) and the University Registrar prior to the start of each semester. This process will be included in the annual financial aid set up process. Estimated Completion Date: 8/31/2025 NVCC Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Corrective Action Planned: Step 1: Ensure proper setup of academic and holiday calendars in the information system. This will include the Director of Financial Aid working closely with the Policy Planning Specialist to ensure the academic calendar and holiday calendars are set up properly in the information system to account for all breaks. Step 2: Improved communications during calendar and information system setups. This will include regular scheduled meetings between the Policy Planning Specialist, Associate Director of Financial Aid Information Systems, and the Director of Financial Aid to review the academic and holiday calendar setups in the information system. Make any appropriate updates to the academic calendar and financial aid setups in the information system. Step 3: Run VCCS Custom R2T4 Report and perform R2T4 calculations/adjustments based on the R2T4 policies and procedures. Estimated Completion Date: 6/30/2025

View Audit 345214

Finding 526131 (2024-091)

Significant Deficiency 2024

Commonwealth of Virginia

VA

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

GMU Responsible Contact Person(s): Alethia Shipman, Director, Student Financial Aid Corrective Action Planned: To enhance and ensure the accuracy and timeliness of Return to Title IV (R2T4) calculations and processes, the Office of Student Financial Aid will implement several corrective actions. The...

GMU Responsible Contact Person(s): Alethia Shipman, Director, Student Financial Aid Corrective Action Planned: To enhance and ensure the accuracy and timeliness of Return to Title IV (R2T4) calculations and processes, the Office of Student Financial Aid will implement several corrective actions. These include increasing personnel to ensure R2T4 calculations are completed promptly, collaborating closely with the Associate Director of Funds Management to ensure funds are returned in a timely manner, coordinating with the Office of the University Registrar to ensure student withdrawals are coded accurately and promptly, and making necessary adjustments to the schedule and review process for reports to ensure compliance. Estimated Completion Date: 12/31/2025 NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Registrar’s Office has documented procedures for running report(s) to identify all students who withdraw within a specific timeframe. A schedule will be created to ensure that the report is run accurately and timely. This will allow timely processing and submission of data by the Financial Aid Office. The Financial Aid Office will utilize the schedule created by the Registrar to ensure that the list of withdrawn students is completed timely. Estimated Completion Date: 8/31/2025 NVCC Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Lisa Boyko, Associate Director of Financial Aid Corrective Action Planned: Step 1: The Associate of Financial Aid, R2T4, will provide additional training to staff member(s) responsible for performing R2T4 calculations and returns. This will include training on R2T4 guidelines, information system generated reports, and review of the college R2T4 policies and procedures. Step 2: Use VCCS Custom R2T4 Report to identify students who are subject to Title IV adjustments/returns. This will include the staff member responsible for R2T4s will use the VCCS Custom R2T4 to perform appropriate calculations and returns for all student identified. Step 3: The Director/Associate Director of Financial Aid, R2T4, will administer quality control of R2T4s. This will include reviewing the R2T4 report to identify outstanding R2T4s. Periodically running information system generated reverse R2T4 report to identify any R2T4s that were not processed. If any R2T4s are identified as unprocessed, the staff member responsible for R2T4s will promptly perform the R2T4 as outlined in the policies and procedures. Estimated Completion Date: 6/30/2025

View Audit 345214

Finding 525976 (2024-002)

None 2024

Converse University

SC

Student Financial Aid Subrecipient Monitoring Reporting

Compliance Requirement Finding: Special Test and Provisions – Enrollment Reporting The University had not reported changes of the sampled graduated or withdrawn students to the National Student Loan Data System (“NSLDS”) as required under the Uniform Grant Guidance for the year ended June 30, 2024, ...

Compliance Requirement Finding: Special Test and Provisions – Enrollment Reporting The University had not reported changes of the sampled graduated or withdrawn students to the National Student Loan Data System (“NSLDS”) as required under the Uniform Grant Guidance for the year ended June 30, 2024, accurately or timely. Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.038, 84.063, 84.268 Corrective Action Plan The finding was due to a lack of a process to correctly backdate administrative withdrawals when a student receives a "W" grade after the withdrawal deadline. This inconsistency led to inaccurate reporting to the National Student Loan Data System (NSLDS) and the academic file. To address this, management has collaborated with the Offices of Campus Technology, Student Financial Services, and the Registrar and has developed and implemented better procedures for handling administrative withdrawals. These procedures will ensure: • Consistent reporting of withdrawal dates to NSLDS. • Ensuring that withdrawal dates are recorded uniformly in both the Registrar’s office and Student Financial Services. • Accurate assignment of "W" grades according to the academic calendar. These new procedures were implemented in the beginning of 2024. The Registrar’s office will continue to submit regular enrollment reports to NSLDS, promptly reporting any changes to student enrollment as required. The Office of the Registrar will be responsible for implementing the corrective action plan, under the supervision of the University Registrar and Director of Institutional Research and Effectiveness. Shannon Bishop Shannon.bishop@converse.edu University Registrar

View Audit 345135

Finding 525914 (2024-001)

Significant Deficiency 2024

Indian Center Housing Corporation

NE

Questioned Costs Internal Control / Segregation of Duties Student Financial Aid

The corrective action plan for the internal controls over expenses paid (2024-001), is summarized as follows: Corrective Action Planned: The Center will review and update its procedures to ensure the proper payment of allowable expenses. Anticipated Completion Date: December 31, 2024. Responsible: M...

The corrective action plan for the internal controls over expenses paid (2024-001), is summarized as follows: Corrective Action Planned: The Center will review and update its procedures to ensure the proper payment of allowable expenses. Anticipated Completion Date: December 31, 2024. Responsible: Management and Board of Directors.

View Audit 345073 Questioned Costs: $1

Finding 525787 (2024-002)

None 2024

Marietta College

OH

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

The College will examine the document destruction date on student related files related to federal compliance requirements to ensure accuracy of the document destruction date and accuracy of student files. Additionally, the College will closeout the Federal Perkins Loan Program in fiscal year 2025.

View Audit 344941

Finding 525665 (2024-002)

Significant Deficiency 2024

Community College District of Gogebic County

MI

Student Financial Aid Internal Control / Segregation of Duties Reporting

Auditor Description of Condition and Effect. During our review of the Fiscal Operations Report and Application to Participate (FISAP), we noted there were errors in the amounts reported. As a result, the College's FISAP was prepared incorrectly and had to be resubmitted to the Department of Federal ...

Auditor Description of Condition and Effect. During our review of the Fiscal Operations Report and Application to Participate (FISAP), we noted there were errors in the amounts reported. As a result, the College's FISAP was prepared incorrectly and had to be resubmitted to the Department of Federal Student Aid. Auditor Recommendation. We recommend that the College implement a secondary review process over the preparation and reporting of the FISAP to ensure proper and accurate reporting. Corrective Action. The College has performed the necessary steps to correct the error and will amend the reporting process to ensure that a second individual is reviewing the work performed. Responsible Person. Maryann DeCaire, Director of Financial Aid. Anticipated Completion Date. April 30, 2025.

View Audit 344780

Finding 525661 (2024-001)

Significant Deficiency 2024

Community College District of Gogebic County

MI

Special Tests & Provisions Student Financial Aid Period of Performance

Auditor Description of Condition and Effect. This condition was caused by a lack of detailed review of the Return to Title IV calculation and days used in the Spring 2024 semester. As a result, four students' Return to Title IV calculations were performed using incorrect start dates for the 2024 Spr...

Auditor Description of Condition and Effect. This condition was caused by a lack of detailed review of the Return to Title IV calculation and days used in the Spring 2024 semester. As a result, four students' Return to Title IV calculations were performed using incorrect start dates for the 2024 Spring semester resulting in an understatement in $84 of Pell awards to the students. The College corrected this issue with the Department of Education on July 30, 2024. Auditor Recommendation. We recommend that the College implement a review process to ensure the number of days used in the Return to Title IV calculation is accurate and that the Return to Title IV calculation is being reviewed by a second individual. Corrective Action. The College has performed the necessary steps to correct the error and will develop a process to ensure that a second individual is reviewing the work performed. Responsible Person. Maryann DeCaire, Director of Financial Aid. Anticipated Completion Date. April 30, 2025.

View Audit 344780

Finding 525639 (2024-005)

Significant Deficiency 2024

Cottey College

MO

Questioned Costs Student Financial Aid Special Tests & Provisions

Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the scheduled end date did not consider finals week, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the...

Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the scheduled end date did not consider finals week, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 2 out of the population of 5 (40%) Spring withdrawal calculations as two students had attended over 60% of the semester for both the original and updated calculations and as such, no return was required. A sample of two Fall withdrawal calculations identified one error (50%) due to incorrect inputs for awards that were disbursed and those that could have been disbursed. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-005. Statistical sampling was not used in making sample selections. Corrective Action Plan: This repeated finding was due to our previously delayed audits. We implemented the plan below on 09/10/2024 after the 2023-05 finding, however, the 2023-24 school year had already completed. This meant we were unable to make changes in the year as it had already concluded, and we implemented the corrective action plan for the 2024-25 school year. 2023-005 Corrective Action Plan: Corrective Action Plan: The Registrar’s Office will review the school calendar in Common Origination and Disbursement Web Site before the financial aid office begins processing R2T4’s for the school year. Responsible Person for Correction Action Plan: Hannah Masters (Executive Director of Financial Aid and Student Accounts) and Chayna Penney (Registrar) Implementation Date for Corrective Action Plan: 09/10/2024 Responsible Person for Correction Action Plan: Hannah Masters Implementation Date for Corrective Action Plan: 01/30/2025

View Audit 344753 Questioned Costs: $1

Finding 525638 (2024-004)

None 2024

Cottey College

MO

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking

Condition: Cottey College did not report the correct loan disbursement dates to the Common Origination and Disbursement (COD) system for 2 of the 37 students in the sample (5.4%). We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is ...

Condition: Cottey College did not report the correct loan disbursement dates to the Common Origination and Disbursement (COD) system for 2 of the 37 students in the sample (5.4%). We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-004. Statistical sampling was not used in making sample selections. Corrective Action Plan: During the month of October 2024, a financial aid consultant met with Cottey staff to discuss and plan better procedures related to awarding and reviewing Federal Loans. Throughout the 2024-25 school year, we have implemented quarterly internal audits where students are randomly selected and processed through an internal review of their federal awards. Through this new process, we are reviewing loan eligibility, disbursement dates, and documentation for each student. By completing this process quarterly, we will be able to do an additional review of each student in detail while the school year is still in session and corrections can be made. Responsible Person for Correction Action Plan: Hannah Masters (Executive Director of Financial Aid and Student Accounts) Implementation Date for Corrective Action Plan: 01/30/2025

View Audit 344753

Finding 525637 (2024-003)

Significant Deficiency 2024

Cottey College

MO

Questioned Costs Student Financial Aid Cash Management

Condition: During our testing of thirty-seven student files, we noted ten individuals (27%) that were not properly awarded Direct Loans. Corrective Action Plan: During the month of October 2024, a financial aid consultant met with Cottey staff to discuss and plan better procedures related to awardi...

Condition: During our testing of thirty-seven student files, we noted ten individuals (27%) that were not properly awarded Direct Loans. Corrective Action Plan: During the month of October 2024, a financial aid consultant met with Cottey staff to discuss and plan better procedures related to awarding and reviewing Federal Loans. Throughout the 2024-25 school year, we have implemented quarterly internal audits where students are randomly selected and processed through an internal review of their federal awards. Through this new process, we are reviewing loan eligibility, disbursement dates, and documentation for each student. By completing this process quarterly, we will be able to do an additional review of each student in detail while the school year is still in session and corrections can be made. Responsible Person for Correction Action Plan: Hannah Masters (Executive Director of Financial Aid and Student Accounts) Implementation Date for Corrective Action Plan: 01/30/2025

View Audit 344753 Questioned Costs: $1

Finding 525636 (2024-002)

None 2024

Cottey College

MO

Questioned Costs Student Financial Aid Eligibility

Condition: During our testing of thirty-seven student files, we noted one individual (2.7%) was not properly awarded Pell grants Corrective Action Plan: During the month of October 2024, a financial aid consultant met with Cottey staff to discuss and plan better procedures related to awarding and r...

Condition: During our testing of thirty-seven student files, we noted one individual (2.7%) was not properly awarded Pell grants Corrective Action Plan: During the month of October 2024, a financial aid consultant met with Cottey staff to discuss and plan better procedures related to awarding and reviewing federal awards. Throughout the 2024-25 school year, we have implemented quarterly internal audits where students are randomly selected and processed through an internal review of their federal awards. Through this new process, we are reviewing Federal Pell, FSEOG and Federal Work Study eligibility, disbursement dates, and documentation for each student. By completing this process quarterly, we will be able to do an additional review of each student in detail while the school year is still in session and corrections can be made. Responsible Person for Correction Action Plan: Hannah Masters (Executive Director of Financial Aid and Student Accounts) Implementation Date for Corrective Action Plan: 01/30/2025

View Audit 344753 Questioned Costs: $1

Finding 525630 (2024-001)

None 2024

Midland Univeristy

NE

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

Corrective Action Planned: The process for disbursement notification will be reviewed. Features of the student information system will be utilized so that the new notification will include specific details of the amount and type of Title IV funds, as well as in formation regarding the right to cance...

Corrective Action Planned: The process for disbursement notification will be reviewed. Features of the student information system will be utilized so that the new notification will include specific details of the amount and type of Title IV funds, as well as in formation regarding the right to cancel any portion of loans to be distributed. Name(s) of Contact Person(s) Responsible for Corrective Action: Doug Watson, Financial Aid Director & Joseph Harnisch, CFO Anticipated Completion Date: The Corrective Action was completed on August 16, 2024.

View Audit 344747

Finding 525614 (2024-005)

Significant Deficiency 2024

Bluefield University

VA

Student Financial Aid Reporting Significant Deficiency

U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Enrollment Reporting (Significant Deficiency). Condition: The University did not report student enrollment data to the National Student Clearinghouse within the minimum required timefr...

U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Enrollment Reporting (Significant Deficiency). Condition: The University did not report student enrollment data to the National Student Clearinghouse within the minimum required timeframe. Criteria: Based on requirements set forth by 34 CFR Section 685.309(b)(2), the University is responsible for notifying the National Student Loan Data System (NSLDS) of changes to student’s enrollment data within minimum required timeframes. Cause: Controls are not functioning properly. Effect: Enrollment data was not reported timely or accurately to the Department of Education thus, the Department could not properly service the student’s loans. The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. Context: From a population of 129 students that withdrew officially or unofficially during a term, we tested 12 students and noted that the withdrawal date was incorrectly reported as the last day of the term for four students and was not reported for one student. In addition, the R2T4 calculation was prepared untimely for four students that required a calculation, as noted in finding 2024-004, and thus the withdrawal dates were reported untimely. Repeat Finding from Prior Year: Not a repeat finding. Recommendation: We recommend that a review process be put in place to ensure timely and accurate enrollment reporting to NSLDS. Corrective Actions: The policy to be developed regarding student withdrawals and R2T4 calculations will specify that students’ withdrawal dates are to be defined as the last date of academic attendance. The policy also will stipulate that, in accordance with National Student Clearinghouse requirements, Bluefield University will submit accurate student enrollment data throughout the academic year.

View Audit 344711

Finding 525613 (2024-004)

Significant Deficiency 2024

Bluefield University

VA

Reporting Student Financial Aid Significant Deficiency

U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Return of Title IV Funds (Significant Deficiency) Condition: The University failed to return Title VI funds to the Department of Education within 45 days of student’s date of determina...

U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Return of Title IV Funds (Significant Deficiency) Condition: The University failed to return Title VI funds to the Department of Education within 45 days of student’s date of determination. Criteria: Return of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew in accordance with 34 CFR Section 668.173(b). Cause: Controls are not functioning properly. Effect: Funds were not timely returned to students or federal agencies as required. Context: From a population of 129 students that withdrew officially or unofficially during a term, we tested 12 students and noted that the R2T4 calculations were required for nine students. Of the nine students, R2T4 calculations were prepared untimely for six students, resulting in a late return of Title IV funds. Repeat Finding from Prior Year: Not a repeat finding. Recommendation: We recommend procedures are put in place to ensure R2T4 calculations are performed timely following the University’s date of determination. Corrective Actions: In February 2025, Bluefield University leadership will work with the combined staff of the University’s Bluefield Central one-stop administrative office to develop and document a policy to ensure that communication from the registrar’s office regarding a student’s official or unofficial withdrawal occurs within 15 days of the student’s withdrawal. The policy also will stipulate that the financial aid staff of Bluefield Central will complete R2T4 calculations within 30 days of the student’s withdrawal, and the University’s business office will return Title IV funds to the Department of Education within 40 days of a student’s withdrawal.

View Audit 344711

Finding 525604 (2024-002)

Significant Deficiency 2024

Central Methodist University

MO

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

Description of Finding: From the testing sample 3 instances were found where student financial aid was incorrectly packaged. All 3 were under awarded loans and or Pell Grants. Statement of Concurrence or Nonconcurrence: Management agrees that in each of the 3 cases, aid was not packaged correctly. C...

Description of Finding: From the testing sample 3 instances were found where student financial aid was incorrectly packaged. All 3 were under awarded loans and or Pell Grants. Statement of Concurrence or Nonconcurrence: Management agrees that in each of the 3 cases, aid was not packaged correctly. Corrective Action: The staff in the financial assistance office has seen a large turnover over the past year. Training continues for those new to packaging. A Pell Report has been developed to automatically identify Pell awards based on the new SAI process. Summer Pell training for eligible students will be held for all staff before the Summer 2025 award period. Name of Contact Person: Dyllon Harper, Director of Financial Assistance, Projected Completion Date: Summer 2025

View Audit 344704

Finding 525603 (2024-001)

Significant Deficiency 2024

Central Methodist University

MO

Student Financial Aid Significant Deficiency

Description of Finding: From the testing sample, six instances were found where credit balances from Title IV balances were not properly refunded to students based on the disbursement dates. Statement of Concurrence or Nonconcurrence: With staff turnover, offices were incurring a longer time to bala...

Description of Finding: From the testing sample, six instances were found where credit balances from Title IV balances were not properly refunded to students based on the disbursement dates. Statement of Concurrence or Nonconcurrence: With staff turnover, offices were incurring a longer time to balance COD approved disbursements to actual disbursements to student accounts. Once the loan disbursements were balanced and confirmed to students, the loan refunds were immediately released to students. CMU is aware of, and normally follows the 14 day policy, but it was determined to hold loan refunds until the loans posted to CMU accounts were correct with COD to avoid incorrect disbursements. Corrective Action: The office of Financial Assistance has identified balancing COD disbursements and internal loan disbursement as a mandatory priority each week. A macro report has been developed to help identify differences with COD and allow corrections and COD draws in a timely fashion. Name of Contact Person: Dyllon Harper, Director of Financial Assistance, Projected Completion Date: Fall 2024

View Audit 344704

Finding 525598 (2024-001)

Significant Deficiency 2024

Allegheny College

PA

Student Financial Aid Reporting Significant Deficiency

Criteria, Condition, Cause: We concur that our timely reporting of academically dismissed students during the non-required summer term is an issue and will be vigilant to prevent this delayed reporting in the fun1re. It should be noted that this small cohort was all deemed ineligible to return for ...

Criteria, Condition, Cause: We concur that our timely reporting of academically dismissed students during the non-required summer term is an issue and will be vigilant to prevent this delayed reporting in the fun1re. It should be noted that this small cohort was all deemed ineligible to return for the upcoming semester on the same day, and so that singular days' enrollment status changes were the only updates that were untimely in the submission to the National Student Loan Data System (NSLDS). We will be modifying and monitoring our process to accurately capture and report to the NSLDS sh1dents determined to be ineligible to return in the fall semester even during a tenn of non-required enrollment. Effect, Questioned costs, Context: Enrollment rosters and updated enrollment statuses are reported regularly with NSLDS to ensure current enrollment status that can impact loan repayment dates and in-school deferments are accurately on record with the Department of Education. For the summer enrollment roster, although Allegheny's summer term is a non-required tern1, students that are not enrolled in the summer tern1, but Allegheny is aware that they will not be enrolled in the upcoming required fall tem1 must be reported as withdrawn through the summer enrollment roster. Recommendation The College will continue to confom1 to the NSLDS reporting process and timeline, and with the collaboration of the Financial Aid's, Registrar's, and Provost's Offices, will fully bring the non-required term enrollment reporting into alignment. For the next non-required summer tern1 enrollment report in 2025, Allegheny will be incorporating the shtdents determined to be academically dismissed from the spring tenn on the initial summer enrollment roster with the updated withdrawn stah1s. The initial summer enrollment roster will be submitted within 60 days.

View Audit 344703

Finding 525559 (2024-004)

Significant Deficiency 2024

Bethany College

KS

Student Financial Aid Reporting Significant Deficiency

Corrective Action Plan 2024-004: The College concurs with the finding and has taken corrective action by submitting a corrected FISAP with the accurate date prior to the FISAP corrections due date of December 13, 2024. Additionally, the College has established controls to ensure review of the Perkin...

Corrective Action Plan 2024-004: The College concurs with the finding and has taken corrective action by submitting a corrected FISAP with the accurate date prior to the FISAP corrections due date of December 13, 2024. Additionally, the College has established controls to ensure review of the Perkins section of the FISAP for the next reporting year. Completion Date: December 2024 Contact Person: Steven W. Eckman, President

View Audit 344637

Finding 525556 (2024-003)

Significant Deficiency 2024

Bethany College

KS

Student Financial Aid Reporting Significant Deficiency

Corrective Action Plan 2024-003: The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to report disbursement dates to COD and has corrected the disbursement date in COD for the student discrepancy noted. Completion Date: February 2024 Conta...

Corrective Action Plan 2024-003: The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to report disbursement dates to COD and has corrected the disbursement date in COD for the student discrepancy noted. Completion Date: February 2024 Contact Person: Steven W. Eckman, President

View Audit 344637

Finding 525554 (2024-001)

Significant Deficiency 2024

Bethany College

KS

Student Financial Aid Cash Management Subrecipient Monitoring

Corrective Action Plan 2024-001: The College concurs with the finding and has adjusted its processes and controls beginning with the Spring 2024 semester to conduct a review of students for which refund payments need to be made prior to drawing down funds from G5. Anticipated Completion Date: Febru...

Corrective Action Plan 2024-001: The College concurs with the finding and has adjusted its processes and controls beginning with the Spring 2024 semester to conduct a review of students for which refund payments need to be made prior to drawing down funds from G5. Anticipated Completion Date: February 2024 Contact Person: Steven W. Eckman, President

View Audit 344637

Finding 525538 (2024-001)

Significant Deficiency 2024

Benedict College

SC

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

Return of Title IV (R2T4) Planned Corrective Action: The College will continue to ensure that the Financial Aid staff is properly and regularly trained on all aspects of Return of Title IV Funds. The staff will participate in any webinars or conferences available. Weekly reports will be produced ...

Return of Title IV (R2T4) Planned Corrective Action: The College will continue to ensure that the Financial Aid staff is properly and regularly trained on all aspects of Return of Title IV Funds. The staff will participate in any webinars or conferences available. Weekly reports will be produced to ensure that all calculations are completed within the 45-day regulation. The Director of Financial Aid will regularly review calculations for accuracy, completeness, and timely return of funds. Person Responsible for Corrective Action Plan: Monique Rickenbaker, Director of Financial Aid and Scholarships Anticipated Date of Completion: July 1, 2025

View Audit 344611

Corrective Action Plans

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