Corrective Action Plans

Finding 520054 (2024-001)

None 2024

The Cleveland Institute of Art and Subsidaries

OH

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

Management acknowledges that there was an error with one over award of subsidized loan on a student. Student was given $448 (gross) over the aggregate subsidized limit. The overage was sent back to the Direct lender. Since the student graduated, the $448 was covered by a grant. A survey of all stude...

Management acknowledges that there was an error with one over award of subsidized loan on a student. Student was given $448 (gross) over the aggregate subsidized limit. The overage was sent back to the Direct lender. Since the student graduated, the $448 was covered by a grant. A survey of all students was completed and no other students were discovered to have been over their aggregate subsidized limit. • A student’s aggregate subsidized amount on NSLDS from his FAFSA record was listed at $17,948, allowing only $5,052 in remaining to reach the $23,000 aggregate limit on subsidized loan. Student was given $5,500 when it should have been $5,052. The $448 should have been given as unsubsidized loan. Student had previous loans from another school. (Powerfaids will catch this error if all of the historic loans were processed within our database.) • The student ISIR record did have Comment code 258: “Based upon data provided by the National Student Loan Data System (NSLDS) and your grade level, we have determined that you may have received a total amount of undergraduate student loans that is close to or equal to the loan limits established for the federal loan programs. Therefore, your eligibility for additional student loans may be limited.“ • The Federal processor usually sends a post-screening after federal aid is disbursed with warnings of limits: 255, 256, 258. 260 ad 261. This would cause a C-code on the student record. We did not receive a subsequent ISIR record on said student. Corrective Action Plan: Include in the Quality Assurance rules one for the ISIR codes associated with NSLDS overawarding of loans whether it be annual limits or aggregate limits. We will monitor these codes regularly during packaging season and subsequent to loan disbursing.

View Audit 339558

Finding 520046 (2024-001)

Significant Deficiency 2024

Transylvania University

KY

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

January 16, 2025 U.S. Department of Education 400 Maryland Ave SW Washington, DC 20212 Transylvania University respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Blue & Company, LLC 250 West Main Str...

January 16, 2025 U.S. Department of Education 400 Maryland Ave SW Washington, DC 20212 Transylvania University respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Blue & Company, LLC 250 West Main Street, Suite 2900 Lexington, Kentucky 40507 The findings from the schedule of findings and questioned costs (the Schedule) for the year ended June 30, 2024 are discussed below and are numbered consistently with the numbers assigned in the Schedule. Identifying Number: 2024-001 Finding: Enrollment Reporting. The enrollment status for students who completed their graduation requirements in May 2024 was incorrect for more than 30 days. Corrective Actions Taken or Planned: This issue occurred because enrollment and degree verify files sent to the National Student Clearinghouse (NSC) at the end of a term were processed in a particular order and student enrollment data overwrote student graduated status data. To correct the impacted students, the university registrar requested that NSC reprocess the May 2024 degree verify file, which should have been processed last. To prevent a future recurrence, the registrar has modified the file upload schedule to reflect the correct order of processing and has updated office procedures to clarify that the degree verify file should be uploaded last, following the submission of all term enrollment data. In addition to altering the file submission schedule, the registrar will ensure the end-of-term enrollment file has been processed by the NSC before the Degree Verify file is submitted each term. January 16, 2025 U.S. Department of Education 400 Maryland Ave SW Washington, DC 20212 Estimated Completion Date: November 11, 2024 Responsible Personnel: Michelle Robinson, Registrar If you have any questions or would like any additional information regarding these matters, please let us know and we will be happy to provide. Sincerely, Lisa Custardo, CPA Chief Financial Officer

View Audit 339546

Finding 519998 (2024-001)

None 2024

Sauk Valley Community College District 506

IL

Student Financial Aid

The audit identified discrepancies between the enrollment information reported to the Clearinghouse and the data reflected in NSLDS, affecting 4 of the 10 student files reviewed by the auditors. The root cause was determined to be a communication breakdown between the Clearinghouse and NSLDS systems...

The audit identified discrepancies between the enrollment information reported to the Clearinghouse and the data reflected in NSLDS, affecting 4 of the 10 student files reviewed by the auditors. The root cause was determined to be a communication breakdown between the Clearinghouse and NSLDS systems, resulting in the transfer of inaccurate data. A corrective action plan has been developed to strengthen internal controls and ensure the accuracy of enrollment reporting. To enhance accuracy, the Registrar and the Director of Financial Assistance will conduct a random review of enrollment reporting data submitted through the National Student Clearinghouse and reflected in NSLDS at regular intervals during each semester and following the confirmation of degrees. This review process will include cross-referencing the last date of attendance and effective withdrawal dates recorded in institutional systems against the corresponding data in the Clearinghouse and NSLDS. Any discrepancies identified during these reviews will be documented, and necessary corrections will be promptly submitted to the Clearinghouse.

View Audit 339433

Finding 519870 (2024-003)

Significant Deficiency 2024

Alexander County

NC

Questioned Costs Special Tests & Provisions Student Financial Aid

Name of Contact Person: Jennifer Herman, Finance Director Corrective Action: 1. The Finance Office will no longer make corrections on employee mileage and meal reimbursement forms submitted by County departments. Finance Office staff will return incorrect forms for departmental personnel to make...

Name of Contact Person: Jennifer Herman, Finance Director Corrective Action: 1. The Finance Office will no longer make corrections on employee mileage and meal reimbursement forms submitted by County departments. Finance Office staff will return incorrect forms for departmental personnel to make corrections and resubmit the reimbursement form. Proposed Completion Date: This plan has been implemented since October 1, 2024. 2. The County will update its travel policy and require County department heads to be responsible for the use of approved rates on employee travel reimbursement forms. Proposed Completion Date: January 1, 2025.

View Audit 339174 Questioned Costs: $1

Finding 519866 (2024-002)

Significant Deficiency 2024

Alexander County

NC

Questioned Costs Special Tests & Provisions Student Financial Aid

Name of Contact Person: Michael Dodson, DSS Business Officer Corrective Action: 1. Alexander County DSS has implemented more detailed Indirect Cost Plan review to ensure that the County Manager signed plan is utilized and not the Final (Draft) version. The Business Officer will further train in t...

Name of Contact Person: Michael Dodson, DSS Business Officer Corrective Action: 1. Alexander County DSS has implemented more detailed Indirect Cost Plan review to ensure that the County Manager signed plan is utilized and not the Final (Draft) version. The Business Officer will further train in the differences between the two documents to ensure the proper one is reviewed and financial data is transferred over to the 1571 mthly cost statements. Proposed Completion Date: Reviewing of the two versions of the Indirect Cost Plans by the DSS Business Officer has been completed as of August 6th, 2024 once the Signed FY23 Indirect Cost plan was obtained. DSS Business Officer will continue a review process every fiscal year once the newly signed plan is received. 2. The DSS Director and Business Office team will review the Official Indirect Cost Plans annually and check the 1571 Statement of Admin. letters mthly to ensure accuracy in the Indirect Cost Plan financial data. Proposed Completion Date: August 6th, 2024

View Audit 339174 Questioned Costs: $1

Finding 519862 (2024-001)

Significant Deficiency 2024

Alexander County

NC

Special Tests & Provisions Student Financial Aid Significant Deficiency

Corrective Action Plan for Finding 2024-001 Name of Contact Person: Michael Dodson, DSS Business Officer Corrective Action: 1. On May 7th and May 17th, job counseling sessions and written warnings were given to the employees who were flagged for not logging out or locking their screens to protect...

Corrective Action Plan for Finding 2024-001 Name of Contact Person: Michael Dodson, DSS Business Officer Corrective Action: 1. On May 7th and May 17th, job counseling sessions and written warnings were given to the employees who were flagged for not logging out or locking their screens to protect confidential information. In addition, On July 2nd, a staff meeting was completed to review agency policy on PII requirements and expectations and I.T. has changed lock out screen settings to take place after 3 minutes of inactivity on all DSS Computer Systems. Proposed Completion Date: PII Policy Enforcement, Training Reviews, Security Implementations have been completed as of 7/2/24. 2. The DSS Director and Agency Admin. team will randomly check office computers to ensure systems are locked per policy. Proposed Completion Date: July 2, 2024

View Audit 339174

Finding 519860 (2024-001)

Significant Deficiency 2024

Salem State University

MA

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster AL #: 84.063 and 84.268 Award year: 2024 Corrective Action Plan: The R2T4 calculations were done in a timely manner. These errors were due to human error and is considered isolated in...

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster AL #: 84.063 and 84.268 Award year: 2024 Corrective Action Plan: The R2T4 calculations were done in a timely manner. These errors were due to human error and is considered isolated incidents. The Financial Aid office has taken great steps over the years and improved the processes for identifying and processing R2T4 calculations in a timely manner. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2024. Contact Person Scott Jewell, Director of Financial Aid

View Audit 339156 Questioned Costs: $1

Finding 519832 (2024-001)

Significant Deficiency 2024

St. John Fisher College and Subsidiaries

NY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

The University recognizes the importance of complying with all federal requirements. In this case out of the sample of students one student was reported late to NSLDS. During the processing of a student's academic status, there was a unique situation where the student's record remained active in our...

The University recognizes the importance of complying with all federal requirements. In this case out of the sample of students one student was reported late to NSLDS. During the processing of a student's academic status, there was a unique situation where the student's record remained active in our system due to the presence of an incomplete grade. In this case, because the incomplete grade delayed the finalization of the student’s academic status, the dismissal was not reported to NSLDS within the typical timeframe. Once the incomplete was resolved and the final status was updated, the necessary information was reported to NSLDS. Measures will be put in place to ensure all changes are processed timely, additional measures are as follows.  Adding the following language to the Graduate catalog, consistent with the Undergraduate catalog: Students with one or more Incomplete grades at the end of the term have an academic standing of On Hold until the Incomplete grade(s) is resolved. When all Incomplete grades are converted to letter grades, the term and cumulative GPA are recalculated and academic standing is set according to the Standards of Academic Progress.  Before any dismissal decision is finalized, the Registrar’s Office verifies that all incomplete grades for the student have been resolved and that final grades are recorded in the system. This verification ensures that no student is dismissed prematurely or inaccurately in the academic records. Implement a workflow process as a double check in the student information system that monitors the status of incomplete grades for students who are dismissed, the system will generate alerts to the Registrar’s office when an incomplete grade is pending resolution in conjunction with dismissal.  Implementing controls to ensure accurate grading in conjunction with dismissals in the Student Information System will enable precise reporting to NSC/NSLDS

View Audit 339019

Finding 519800 (2024-001)

Material Weakness 2024

Claiborne Parish School Board

LA

Cash Management Student Financial Aid

Reference # and title: 2024-001 Controls over Cash Management Federal program and specific federal award identification: CFDA Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Education; passed through Louisiana Department of Education Title IV – S...

Reference # and title: 2024-001 Controls over Cash Management Federal program and specific federal award identification: CFDA Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Education; passed through Louisiana Department of Education Title IV – SSAE 84.424 2024 Stronger Connections Grant Program 84.424F 2023 Condition found: Good internal controls require that all requests for reimbursement submitted to the Louisiana Department of Education (LDOE) are adequately reviewed and approved either before submission or after submission, but in a timely manner, to ensure amounts reported are complete and accurate. In testing a sample of a requests for reimbursements across all SSAE grants, it was noted that for the Stronger Connections Grant, the request for reimbursement was not reviewed and approved in a timely manner, in which the review and approval did not occur until three months after submission. When testing a sample of claims for reimbursements for the Title IV grants, it was noted that the reimbursements were not reviewed and approved by the supervisor. It was further noted that these reports were not printed until the auditor had requested them and were signed off by someone other than the supervisor as required by the procedures of the School Board. Corrective action planned: The Grants Supervisor has worked to update these procedures for the grants department. To ensure a proper review process is followed, the grants secretary will complete the reimbursement request in the system and the Grants Supervisor will review the request. If correct, the Grants Supervisor will submit the request to LDOE ensuring all request are reviewed before they are submitted. All requests will be printed and signed by the supervisor as the requests are submitted.

View Audit 339000

Finding 519782 (2024-002)

Significant Deficiency 2024

North Central University

MN

Cash Management Student Financial Aid

There is no disagreement with the audit finding. Corrections to the drawdown process will be made. We have implemented new review and reconciliation procedures to ensure that our federal funds drawdown processes are correctly executed in a timely manner.

View Audit 338943

Finding 519780 (2024-001)

Significant Deficiency 2024

North Central University

MN

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

There is no disagreement with the finding. The program length will be corrected for all students. In response to the findings from 2023, North Central corrected all program lengths within our Enterprise Resource Planning (ERP) system, Ellucian’s Colleague. Throughout the academic year, the Registrar...

There is no disagreement with the finding. The program length will be corrected for all students. In response to the findings from 2023, North Central corrected all program lengths within our Enterprise Resource Planning (ERP) system, Ellucian’s Colleague. Throughout the academic year, the Registrar’s Office and Financial Aid Department conducted thorough quality checks of the source data to ensure accuracy. Despite these efforts, unforeseen errors in enrollment data arose due to a data conversion issue between Colleague and the National Student Clearinghouse, which transmits information to the National Student Loan Data System (NSLDS). To address this, we will maintain our semesterly data confirmation process but will shift the primary focus of our reviews to the output data transmitted to NSLDS, ensuring data integrity at every stage of reporting.

View Audit 338943

Finding 519769 (2024-012)

Significant Deficiency 2024

Bishop State Community College

AL

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

Management's Response: Management concurs with the audit finding above. The Director of Admissions & Records has worked with the Audit Resource team at NSC to work through a process to ensure that unofficial withdrawals are accurately captured from Banner and reported in a timely manner. The NSC spe...

Management's Response: Management concurs with the audit finding above. The Director of Admissions & Records has worked with the Audit Resource team at NSC to work through a process to ensure that unofficial withdrawals are accurately captured from Banner and reported in a timely manner. The NSC specialist helped the college set up an additional "subsequent of term" submission roughly 30 days after the end of the semester but prior to the first upload of the following semester. As a nonattendance taking institution, this timeframe will allow the college a chance to make withdrawal determinations for students who did not officially withdraw but stopped attending at some point in the semester and code them appropriately in Banner. This action has occurred, been tested and implemented as of January 2025.

View Audit 338909

Finding 519712 (2024-003)

Significant Deficiency 2024

Southwestern College

KS

Student Financial Aid Reporting Significant Deficiency

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Southwestern now has an internal review in place to ensure that all calculations are done within the time allotment for the R2T4. We are also working very closely with the Registrar’s Office to ensure that all withdrawals are su...

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Southwestern now has an internal review in place to ensure that all calculations are done within the time allotment for the R2T4. We are also working very closely with the Registrar’s Office to ensure that all withdrawals are submitted to our office timely. Person Responsible for Corrective Action Plan: Brenda Hicks, Associate Vice President of Student Financial Planning and Director of Financial Aid Anticipated Date of Completion: Ongoing, process began in October, 2024.

View Audit 338814

Finding 519702 (2024-002)

Significant Deficiency 2024

Prescott College, Inc.

AZ

Student Financial Aid Reporting Significant Deficiency

National Student Loan Database System (NSLDS) Enrollment Reporting Recommendation: We recommend the College reevaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is ...

National Student Loan Database System (NSLDS) Enrollment Reporting Recommendation: We recommend the College reevaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar will re-evaluate policies, procedures and training materials to ensure timely and accurate reporting. Name(s) of the contact person(s) responsible for corrective action: Michele Peterson Planned completion date for corrective action plan: 03/31/2024

View Audit 338798

Finding 519695 (2024-004)

Significant Deficiency 2024

Lake County Community College District

OH

Student Financial Aid Subrecipient Monitoring Cash Management § 200.302 § 200.305

Finding Number: 2024-004 Condition: The College does not have a written cash management policy related to federal awards. Planned Corrective Action: In accordance with 2 CFR 200.302(b)(6), the College will establish a written cash management policy, including written procedures related to fed...

Finding Number: 2024-004 Condition: The College does not have a written cash management policy related to federal awards. Planned Corrective Action: In accordance with 2 CFR 200.302(b)(6), the College will establish a written cash management policy, including written procedures related to federal payments/awards in order to implement the requirements of 200.305. Contact person responsible for corrective action: David Cummins, Vice President for Administrative Services and College Treasurer Anticipated Completion Date: As soon as possible moving forward starting December 18, 2024.

View Audit 338777

Finding 519693 (2024-003)

Material Weakness 2024

Lake County Community College District

OH

Student Financial Aid Internal Control / Segregation of Duties Material Weakness § 200.303

Finding Number: 2024-003 Condition: There was a lack of internal controls in place related to the review of the FISAP that was submitted by the College in September 2023. Planned Corrective Action: The College will establish the proper controls to ensure that the information included in the FISAP...

Finding Number: 2024-003 Condition: There was a lack of internal controls in place related to the review of the FISAP that was submitted by the College in September 2023. Planned Corrective Action: The College will establish the proper controls to ensure that the information included in the FISAP is accurate, including implementing an additional level of review of the report. Contact person responsible for corrective action: David Cummins, Vice President for Administrative Services and College Treasurer Anticipated Completion Date: As soon as possible moving forward starting December 18, 2024.

View Audit 338777

Finding 519690 (2024-002)

Material Weakness 2024

Lake County Community College District

OH

Student Financial Aid Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.303

Finding Number: 2024-002 Condition: There was a lack of internal controls in place related to the return of Title IV funds. Planned Corrective Action: The College will implement controls related to returns of Title IV funds, to ensure the related calculations are complete and accurate, and the fun...

Finding Number: 2024-002 Condition: There was a lack of internal controls in place related to the return of Title IV funds. Planned Corrective Action: The College will implement controls related to returns of Title IV funds, to ensure the related calculations are complete and accurate, and the funds are returned in a timely manner. Contact person responsible for corrective action: David Cummins, Vice President for Administrative Services and College Treasurer Anticipated Completion Date: As soon as possible moving forward starting December 18, 2024.

View Audit 338777

Finding 519674 (2024-003)

Significant Deficiency 2024

San Diego Community College District

CA

Student Financial Aid Reporting Significant Deficiency

Processes will be implemented to review, update and verify data captured by NSLDS and ensure such data has been accurately reported in a timely manner.

View Audit 338758

Finding 519612 (2024-002)

Significant Deficiency 2024

Cleary University

MI

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A new Registrar was hired in late May of 2024. A new process was implemented for the Fall semester of 2024 to ensure timely and accurate processing of official and unofficial withdrawals. Outcom...

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A new Registrar was hired in late May of 2024. A new process was implemented for the Fall semester of 2024 to ensure timely and accurate processing of official and unofficial withdrawals. Outcome: All student withdrawal requests both official and unofficial are processed daily and tracked in a shared workbook. This allows information about each individual withdrawal request to be captured and available for both the Business Office and Financial Aid. Date of Determination, Last Date of Attendance, Processed Date, withdrawal type, withdrawal reason, and credits impacted are all captured in the workbook to aid with R2T4 calculations. This workbook also serves as a document that can be audited in real-time to ensure accuracy of each student’s record. A Standard Operating Procedure was developed and used to train the team members effective on 8/12/2024. Person Responsible for Corrective Action Plan: Tonya Troka, University Registrar & Assistant Provost Anticipated Date of Completion: Completed and implemented for Fall 2024 Semester

View Audit 338706

Finding 519609 (2024-001)

Material Weakness 2024

Cleary University

MI

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

Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Planned Corrective Action: See Below Cleary University identified compliance gaps in its Return of Title IV Funds (R2T4) reporting processes during the 2023-2024 award year. These issues stemmed from a lack of timely enforcement of ...

Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Planned Corrective Action: See Below Cleary University identified compliance gaps in its Return of Title IV Funds (R2T4) reporting processes during the 2023-2024 award year. These issues stemmed from a lack of timely enforcement of procedures and misinterpretation of R2T4 regulatory requirements, necessitating immediate corrective action and leadership changes. The Financial Aid Director was dismissed, and an experienced Assistant Vice President (AVP) of Financial Aid was hired to oversee compliance and ensure accurate implementation of federal regulations. Additional Financial Aid Data Specialists were hired to improve system efficiency and accuracy. An R2T4 Task force was established, meeting weekly to review Last Day of Attendance (LDA) data, monitor student drop processes, and ensure timely R2T4 calculations and funds returned. A structured process for R2T4 calculations was put in place, with cross-referencing from the Records Department, maintaining through documentation, and improving tracking and reporting. Cleary University has taken significant steps to address the issues and ensure compliance with R2T4 regulations. The revised process, implemented in July 2024, aims to prevent future delays and findings. Weekly checks and ongoing training will ensure that R2T4 processing is accurate, timely, and fully complaint with federal requirements, with a target processing completion of 20 days. Person Responsible for Corrective Action Plan: JoAnn Ross, Vice President of Financial Aid Anticipated Date of Completion: December 18, 2024

View Audit 338706

Finding 519587 (2024-001)

Significant Deficiency 2024

Desert Community College District

CA

Student Financial Aid Reporting Significant Deficiency

While reviewing the follow up questions along regarding enrollment reporting, a discovery was made that there could have been issues with the query that was used to create the lists to be sent to National Student Clearinghouse. A new version of the query was created mid-July 2023. This query was lac...

While reviewing the follow up questions along regarding enrollment reporting, a discovery was made that there could have been issues with the query that was used to create the lists to be sent to National Student Clearinghouse. A new version of the query was created mid-July 2023. This query was lacking 3 current student statuses that would have prevented them from picked up transmitted/uploaded to National Student Clearinghouse. The original query was missing a status that was introduced in 2023, which was around summer/spring 2023, which is why the second query was created to pull that new status. Moving forward, we will create a new query for all future reports that use all current statuses.

View Audit 338695

Finding 519539 (2024-004)

Significant Deficiency 2024

Life University, Inc.

GA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Individuals Responsible for Corrective Action Plan: Collections Coordinator (Victoria Beeston)- Responsible for initiating contact with the borrower, providing documentation instructions, and reviewing completed forms. Director of Student Accounts (Ti Jolly)- Responsible for ensuring compliance wi...

Individuals Responsible for Corrective Action Plan: Collections Coordinator (Victoria Beeston)- Responsible for initiating contact with the borrower, providing documentation instructions, and reviewing completed forms. Director of Student Accounts (Ti Jolly)- Responsible for ensuring compliance with all applicable regulations and reviewing the re-assignment documentation. ECSI (Angela Johnson)- Responsible for updating financial records and confirming the reassignment of collection rights. Condition: Federal regulation 34 CFR 674.19(e) and 34 CFR 674.31 indicates that the institution is responsible for creating and maintaining the Master Promissory Note to indicated specifications. The university has found that the existing Master Promissory Note (MPN) or equivalent documentation that acknowledges the debt is either incorrect, incomplete, or missing. Management’s Corrective Action Plan: The following steps outline the corrective actions that will be taken to resolve this issue: 1. Contact the Borrower - Life University will initiate contact with the borrower to inform them of the need to update or establish a new MPN or equivalent documentation. This will be done via the following communication channels: • Phone call (if available) • Email notification • Postal mail (if no response is received through other means) 2. Provide Clear Instructions for Documentation - The university will send a formal notice to the borrower detailing the need for a new MPN or equivalent documentation. This will include instructions on how to sign the new agreement, the importance of the MPN, and a clear explanation of the implications for the outstanding loan amount. 3. Reassign Collection Rights - Once the borrower has completed the required documentation, Life University will work with ECSI to reassign the university’s right to collect on the remaining balance. 4. Documentation Review and Verification - After the MPN is completed by the borrower, Life University will review the new MPN for completeness and accuracy. This review will ensure that the terms are correctly documented, that the borrower’s consent is properly obtained, and that the right to collect on the outstanding amount is clearly assigned. 5. Update Financial Records - Life University will update its financial records to reflect the new MPN and the re-assigned collection rights. The university will also ensure that any outstanding amounts and repayment schedules are updated accordingly. 6. Ongoing Communication and Monitoring - The university will maintain communication with the borrower throughout the process, providing reminders if necessary. Verification of Effectiveness: Upon completion of the corrective actions, the university will verify that: • The borrower has submitted the new MPN or equivalent documentation. • The collection rights have been successfully reassigned. • Financial records have been updated accurately. The university will conduct a follow-up review in February 2025 to verify the effectiveness of the corrective action plan and to ensure that no further issues remain. Anticipated Completion Date: January 1st, 2025

View Audit 338574

Finding 519538 (2024-003)

Significant Deficiency 2024

Life University, Inc.

GA

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

Individuals Responsible for Corrective Action Plan: Michelle Nixon- Assistant Director of Financial Aid Systems. Melissa Waters- Senior Director of Student Administration and Compliance Condition: Finding related to disbursement record to Common Origination and Disbursement (COD) system in excess...

Individuals Responsible for Corrective Action Plan: Michelle Nixon- Assistant Director of Financial Aid Systems. Melissa Waters- Senior Director of Student Administration and Compliance Condition: Finding related to disbursement record to Common Origination and Disbursement (COD) system in excess of 15 days This student’s disbursement occurred on 10/2/23 and LU verified that a disbursement record was sent to COD on 10/2/23; however, this student was not included in that record. We are unable to determine why the student was not included in that disbursement record. We send up disbursement records to COD 3 times a week. The student’s disbursement was transmitted to COD on 10/20/23. Management’s Corrective Action Plan: After speaking with a Common Originations and Disbursement (COD system representative, she stated that schools will receive a Warning Edit 055 when record of disbursement has not been received after 30 days. She verified that we did not receive this Warning Edit 055 from COD because we had not exceeded 30 days. The COD rep went on to share that this 15-day regulation used to be a 30-day regulation, but COD has not updated their Warning Edit 055 process to notify schools. It’s only done after 30 days. COD rep did identify a report Michelle will run to identify anyone who is not showing up with a disbursement record prior to the 15 days. The COD report is called the Anticipated Disbursement Queue and will be ran every 14 days to identify any potential issues. Anticipated Completion Date: January 1st, 2025

View Audit 338574

Finding 519534 (2024-002)

Significant Deficiency 2024

Life University, Inc.

GA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Individuals Responsible for Corrective Action Plan: Jana Holwik- Chief Academic Officer Elizabeth Geisz- Registrar Melissa Waters- Senior Director of Student Administration and Compliance Condition: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in ...

Individuals Responsible for Corrective Action Plan: Jana Holwik- Chief Academic Officer Elizabeth Geisz- Registrar Melissa Waters- Senior Director of Student Administration and Compliance Condition: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days. Management’s Corrective Action Plan: The University will report to the National Student Clearing (NSC) House using regularly scheduled enrollment reports every 30 days. Suppose a student’s enrollment status is not captured in the regularly scheduled enrollment reports with the NSC. In that case, the enrollment reporting will be reported directly to the National Student Loan Database Service (NSLDS), such as after the end of the term once grades are processed. The enrollment reporting in which a student receives a failing grade of all “Fs” for a quarter will be adjusted to meet the reporting time frame. Anticipated Completion Date: January 1st, 2025

View Audit 338574

Finding 519526 (2024-001)

Significant Deficiency 2024

Palomar Community College District

CA

Student Financial Aid Period of Performance Reporting

The audit identified that inaccurate program start dates were recorded due to poor report programming and the absence of clear internal policies governing the program date. The root cause of this issue appears to be poor report programming practices, compounded by a lack of a well-defined internal ...

The audit identified that inaccurate program start dates were recorded due to poor report programming and the absence of clear internal policies governing the program date. The root cause of this issue appears to be poor report programming practices, compounded by a lack of a well-defined internal policy to guide the accurate reporting of program start dates. In response to the finding, the NSC enrollment report has been rewritten with improved programming and internal quality control measures. A more robust process is being implemented to ensure data accuracy moving forward. The new report will be in place for Spring 2025. By addressing both the technical and procedural gaps, Palomar College will enhance the accuracy of program start dates and ensure better alignment with NSC reporting requirements.

View Audit 338531

Corrective Action Plans

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