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Finding 2024-001 Significant Deficiency in Internal Control over Compliance and Other Matters Odessa College will implement the following to ensure compliance with federal regulations, improve internal processes, and prevent future occurrences. Additionally, the college is moving forward with compr...
Finding 2024-001 Significant Deficiency in Internal Control over Compliance and Other Matters Odessa College will implement the following to ensure compliance with federal regulations, improve internal processes, and prevent future occurrences. Additionally, the college is moving forward with comprehensive financial aid advisory services with Ellucian, the College’s enterprise student information system. The engagement/advisory priorities include establishing an R2T4 Process that complies with the 45-day reporting requirement. The engagement period is contracted for the next 14 months. Review and Update Withdrawal Procedures:  Conduct a comprehensive review of current student withdrawal procedures to identify any weaknesses or delays in processing withdrawal dates and the return of Title IV funds.  Ensure that the withdrawal process is thoroughly documented, and that all departments (registrar, financial aid, student accounts) are aligned on their responsibilities related to withdrawal processing. Strengthen Communication between Departments:  Establish a clear communication protocol among the registrar’s office, financial aid office, and student accounts to ensure that withdrawals are processed promptly.  Designate specific individuals to monitor the return of Title IV funds and ensure deadlines are met.  Implement an internal checklist for verifying that all Title IV funds are returned within the required time frame. Implement a Monitoring System:  Set up an automated system or a shared calendar to track Title IV refund timelines for students who withdraw.  Use alerts or reminders to notify responsible staff members when a Title IV refund is due to be returned within the 45-day window.  Monitor and document all returns of Title IV funds to maintain compliance. Staff Training:  Conduct training for staff involved in student withdrawals, financial aid, and compliance to ensure they are knowledgeable about the 45-day return requirement and the importance of adhering to it.  Include a review of the audit finding and corrective actions during departmental Develop a Compliance Audit Checklist:  Create a detailed audit checklist for Title IV refund procedures to be used in periodic internal audits to ensure that all financial aid disbursements, returns, and related processes comply with federal regulations.  Review the checklist regularly to ensure the process is effective and compliant with regulatory changes. Monitoring and Reporting:  Schedule and conduct regular internal audits of Title IV funds return procedures and withdrawal processes to ensure ongoing compliance.  Review audit findings, staff performance, and timelines to identify potential areas for improvement. Compliance Reporting:  Prepare a report for the administrative team outlining corrective actions taken, including the return of funds, updated procedures, and staff training. Responsible Officials: Kim McKay – Vice President Student Services Anticipated Date of Completion: May 2025 meetings to reinforce the importance of compliance.
FINDING 2024-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Management’s Response: The College accepts this finding and has implemented the corrective plan below to reinforce established policies and procedures to ensure file documentation would identify student...
FINDING 2024-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Management’s Response: The College accepts this finding and has implemented the corrective plan below to reinforce established policies and procedures to ensure file documentation would identify students in the return funds population. Plan: South Suburban College established a control process to assist with remaining in compliance as stated in the Single Audit Report Finding 2023-003 Corrective Plan. South Suburban College’s Financial Aid Department used Information Technology reports to retrieve the college’s Return of Title IV funding (R2T4) population, it was found that the reporting files were incorrect. Therefore, the Director of Financial Aid, Financial Manager will review the student population list provided by IT to ensure the population consist of financial aid eligible students who withdrew from all enrolled courses. The Director of Financial Aid will continue to work with the Information Technology Department to enhance the retrieval of the Return of Title IV funding student populations reporting process through Ellucian Colleague per the 2023 Correction Plan.
View Audit 336959 Questioned Costs: $1
FINDING 2024-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Management’s Response: The college accepts this finding and has implemented the corrective plan below. The error was remedied by correcting the enrollment dates in the Colleague student information syst...
FINDING 2024-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Management’s Response: The college accepts this finding and has implemented the corrective plan below. The error was remedied by correcting the enrollment dates in the Colleague student information system. Plan: South Suburban College has and will continue to review procedures to identify areas of improvement for attendance reporting to ensure funds are returned accurately and timely. Enrollment dates will be confirmed and entered in the Colleague system prior to the start of academic year by the Financial Aid Director and Financial Aid Manager to support accurate return of funds calculations. This corrective plan has been implemented. Anticipated Date of Completion: 1/31/2025 Name of Contact Person: Yolanda Freemon
FINDING 2024-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON ORIGINATION AND DISBURSEMENT Management’s Response: The College accepts this finding and has implemented the corrective plan below to reinforce established procedures regarding timely submission of COD information. The error ...
FINDING 2024-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON ORIGINATION AND DISBURSEMENT Management’s Response: The College accepts this finding and has implemented the corrective plan below to reinforce established procedures regarding timely submission of COD information. The error was caused by the cyber incident which delayed submission. Plan: South Suburban College established a control process to assist with remaining in compliance with COD submissions as stated in the Single Audit Report Finding 2023- 003 Recommendation section. In addition, cross-training of the Financial Aid Manager and Financial Aid Coordinator to support timely COD submissions and Pell disbursements was provided. Currently, the disbursement process of PELL consists of weekly submissions by the Financial Aid Coordinator who also requests and reconciles Pell funds in COD. The Financial Aid Director provides additional review of the Pell disbursement lists to ensure accuracy of the awards. This corrective plan has been implemented. Date of Completion: 8/21/2024 Name of Contact Person: Yolanda Freemon
Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The Financial Aid Office will include weekends in the break days identified in the Return to Title IV schedules created on the COD.gov site. All federal aid will be included in R2T4 calculations. These two issues which came out in...
Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The Financial Aid Office will include weekends in the break days identified in the Return to Title IV schedules created on the COD.gov site. All federal aid will be included in R2T4 calculations. These two issues which came out in the audit were resolved and implemented before the fall 2024 semester. Another person will review the R2T4 form before the process is finalized. Person Responsible for Corrective Action Plan: Wes Brothers, Financial Aid Director Anticipated Date of Completion: 08/15/2024
Ineligible Disbursements Planned Corrective Action: The Financial Aid Office will review the credit hours earned for each student to ensure the federal loan amounts awarded are appropriate for the number of hours the student earned. This will be done before the beginning of each semester and after f...
Ineligible Disbursements Planned Corrective Action: The Financial Aid Office will review the credit hours earned for each student to ensure the federal loan amounts awarded are appropriate for the number of hours the student earned. This will be done before the beginning of each semester and after final grades have been posted. Person Responsible for Corrective Action Plan: Wes Brothers, Financial Aid Director Anticipated Date of Completion: 12/9/2024
View Audit 336933 Questioned Costs: $1
Reference Number: 2024-002 Finding: Other Instance of Noncompliance and Deficiency Status: In-progress Corrective Action: The University did not complete a Return to Title IV refund calculation within 45 days after a student had withdrawn from UST. The Assistant Director of Financial Aid ru...
Reference Number: 2024-002 Finding: Other Instance of Noncompliance and Deficiency Status: In-progress Corrective Action: The University did not complete a Return to Title IV refund calculation within 45 days after a student had withdrawn from UST. The Assistant Director of Financial Aid runs a query once a month to find students who have received Title IV or state aid and have withdrawn. The student in question did not appear on the query when we believe they should have, but was on the subsequent report. We have changed our procedures to run the query and complete Return to Title IV calculations weekly, rather than monthly. We believe this will help us find any discrepancies more quickly. We also reviewed the query and made some edits to attempt to increase accuracy. Person(s) Responsible for Implementing: Lynda McKendree, Dean of Scholarships and Financial Aid and Thuylieu Aligo, Assistant Director of Scholarships and Financial Aid Implementation Date: 09/01/2024
Reference Number: 2024-001 Finding: Other Instance of Noncompliance and Significant Deficiency Status: In-progress Corrective Action: Following our analysis, we have concluded that adjusting our data transmission schedule to NSC will help prevent future last minute data anomalies, ensuring that...
Reference Number: 2024-001 Finding: Other Instance of Noncompliance and Significant Deficiency Status: In-progress Corrective Action: Following our analysis, we have concluded that adjusting our data transmission schedule to NSC will help prevent future last minute data anomalies, ensuring that a final transmission for the term always occurs after the end date of each term. Additionally, we have identified a potential issue where NSC may fail to send graduate records to NSLDS for students who immediately re-enroll in the subsequent semester. Due to timing between the submission from NSC to NSLDS, the newer enrollment appears to be overriding the previously sent graduation record, preventing the graduation record from being sent to NSLDS. To address this, we will create a dedicated report to identify students in this situation and manually update NSLDS with the missed graduation data. Finally, there were isolated cases where a historical date adjustment was made to generate an auxiliary outcome (e.g., a grade change of Withdrawal instead of Withdrawal Failing), which made it appear as though a record change wasn't submitted in a timely manner. For these, we will discontinue this practice and employ an alternative method to derive the desired outcome (e.g., additional grade change transactions input after the withdrawal with no date adjustment). Person(s) Responsible for Implementing: Mike Acosta, Institutional Analyst, Nathan Dugat, Registrar, Lynda McKendree, Dean of Scholarships and Financial Aid Implementation Date: 11/01/2024
Recommendation: We recommend that the District implements a process that will ensure all Title IV funds are awarded at proper amounts. Action taken in response to finding: Student’s award was adjusted to appropriately match the EFC of a subsequent ISIR that had not been processed at the time of awa...
Recommendation: We recommend that the District implements a process that will ensure all Title IV funds are awarded at proper amounts. Action taken in response to finding: Student’s award was adjusted to appropriately match the EFC of a subsequent ISIR that had not been processed at the time of awarding. Evidence of that change was provided to auditors in July 2024. Refresher training was provided to analysts to improve monitoring the output files of the ISIR import process (RCRTPxx) that identifies subsequent ISIRs received for students with locked records. Names of the contact persons responsible for corrective action: Patrick Scott and Anna Marie Troupe Planned completion date for corrective action plan: July 2024
View Audit 336749 Questioned Costs: $1
Recommendation: We recommend the District re-evaluate their procedures for providing up-to-date URL information to the Department of Education. Action taken in response to finding: This is a relatively new requirement that was overlooked, and we are happy that the auditors found it. The District ha...
Recommendation: We recommend the District re-evaluate their procedures for providing up-to-date URL information to the Department of Education. Action taken in response to finding: This is a relatively new requirement that was overlooked, and we are happy that the auditors found it. The District has submitted the URL for its contracts with BankMobile to the Department’s website. If the URL for those contracts should change, then the District will need to update those URLs. Please note that the public-facing database of those URLs is updated irregularly—the last update was in January of 2024—and any future submission should have a date stamp somehow attached for future audits. There is a very real possibility that a school could provide this information, but not have it reflected in the database. Names of the contact person responsible for corrective action: Patrick Scott, Dean –Financial Aid, Anna Marie Troupe, Financial Aid Supervisor Planned completion date for corrective action plan: December 2024
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Action taken in response to finding: As this is a multi-year finding, the Financial Aid department and the Business Services department ha...
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Action taken in response to finding: As this is a multi-year finding, the Financial Aid department and the Business Services department have been working closely this term to develop a coordinated approach to avoid the issue going forward. Our procedures have been changed drastically. Once a student appears on a timeout / stale-dated check report from the vendor responsible for delivering aid to our students, we are reversing the funds and processing that reversal through COD first, then reaching out to the student to see if they need to make arrangements for correcting their address. This was done in the opposite fashion in prior years, and while it reduced delays for students who could rectify things, it carried too much risk of being forgotten and the 240 day mark being surpassed. The financial aid department has committed to placing the reversals and processing them through COD within seven business days of receiving the notification from the vendor and/or Business Services. This is far stricter than the federal regulations, but a seemingly necessary step to ensure compliance. Additionally, the Business Services team is aware of the impossibility of delivering aid beyond 240 days of the original check issuance and is helping the financial aid team to understand issuance dates in situations where Title IV aids may be commingled with other financial aid across multiple disbursement attempts. This coordination will ensure the District’s compliance going forward. Name of the contact person responsible for corrective action: Patrick Scott, Dean – Financial Aid, Shannon Beckham –Director of Business Services Planned completion date for corrective action plan: December 2024
View Audit 336749 Questioned Costs: $1
Recommendation: We recognize the District made corrective action after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. We recommend the District continue to follow those controls put in place to ensure compliance with the aforementioned criteria. Action taken i...
Recommendation: We recognize the District made corrective action after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. We recommend the District continue to follow those controls put in place to ensure compliance with the aforementioned criteria. Action taken in response to finding: The District reviewed its enrollment reporting procedures and ensured that information—especially the effective date of status changes—is accurately reported to NSLDS as required by regulations. Name of the contact persons responsible for corrective action: Alysa Borelli, Dean—Enrollment Services, and Patrick Scott, Dean – Financial Aid Planned completion date for corrective action plan: These corrections were already put into place during Fall 2023 when the issue was discovered in the FY 2023 audit.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Action taken in response to finding: As this finding has occurred in multiple years, it is one of the financial aid team’s top priorities. Return to Ti...
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Action taken in response to finding: As this finding has occurred in multiple years, it is one of the financial aid team’s top priorities. Return to Title IV calculations are complex operations—especially in the California Community College system where multiple Pell awards per term and high withdrawal rates are common—that require time and focus. This year’s batch of calculations were problematic due for several reasons: • Human error • Insufficient number of staff capable of reliably performing calculations • Failure to retain students who have received financial aid beyond the 60% mark of the term • A typographical error in the college’s end date for Fall 2023 required us to re-calculate all Return to Title IV calculations, making each of those calculations a technical violation of Title IV regulations since they were done outside the limited time window We have taken the following actions: • Increased the number of people in the department who are capable of performing calculations • Provided support for two staff members to obtain their NASFAA certification in Return to Title IV funds calculations • Requested out-of-class status to remunerate one of our student services assistants who obtained that certification so that they can be involved in these calculations going forward • Emphasized the importance of timely calculations in staff meetings and evaluations • Altered our procedures to include deliberate consideration of dates involved to better control the timeliness of both calculations and returning funds to the Title IV programs. • Added a step to the new aid year setup that verifies that the term start, and end dates entered in the Banner® system are correct. Names of the contact persons responsible for corrective action: Patrick Scott, Dean – Financial Aid, and Anna Marie Troupe, Financial Aid Supervisor Planned completion date for corrective action plan: January 2025
Finding 518362 (2024-001)
Significant Deficiency 2024
2024‐001 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379) Name of Contact Perso...
2024‐001 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379) Name of Contact Person The Director of Financial Aid, Christin Mustard, is responsible for the corrective action plan for this finding. Corrective Action Plan We agree with this finding. After review of this student’s Return to Title IV calculation, it was determined that upon beginning the calculation in the PowerFAIDS system, the Refresh button was not used which would have recalculated the completed days to include the 9-day Spring Break. After reviewing this procedure with PowerFAIDS, it was recommended that we also enter the withdrawal date on the R2T4 tab of the POE screen which forces the system to recalculate the completed days prior to beginning the R2T4 calculation. We have added this step to our Return to Title IV procedures. Anticipated Completion Date The corrected Return to Title IV calculation was completed, which resulted in an Unsubsidized loan return of $1,029. The loan funds were returned via the Common Origination and Disbursement (COD) system.
View Audit 336746 Questioned Costs: $1
2024-003: Student Financial Audit Cluster - Reporting (Significant Deficiency) Corrective Action: Controls have been implemented to retain the documentation used in preparing the FISAP. All documentation for all pieces of the FISAP are now being stored electronically in a shared drive as well as on...
2024-003: Student Financial Audit Cluster - Reporting (Significant Deficiency) Corrective Action: Controls have been implemented to retain the documentation used in preparing the FISAP. All documentation for all pieces of the FISAP are now being stored electronically in a shared drive as well as on paper to be held in the Director’s office. Anticipated Completion Date: 9/13/2024 Contact Person: Laurie Johnstone
2024-005: Student Financial Audit Cluster - Special Tests and Provisions: Enrollment Reporting (Significant Deficiency) Corrective Action: Upon investigation, we discovered that even though Casper College is reporting our enrollment to the National Student Clearinghouse (NSC) in a timely fashion, t...
2024-005: Student Financial Audit Cluster - Special Tests and Provisions: Enrollment Reporting (Significant Deficiency) Corrective Action: Upon investigation, we discovered that even though Casper College is reporting our enrollment to the National Student Clearinghouse (NSC) in a timely fashion, those reports are not always being sent to the National Student Loan Data System (NSLDS) swiftly. We understand that NSC is a third-party servicer and ultimately, the institution is responsible for ensuring NSLDS is being updated properly. As a failsafe, Casper College has developed an internal audit procedure to manually update students in NSLDS to be in compliance with CFR 690.83. Anticipated Completion Date: 9/18/2024 Contact Person: Laurie Johnstone
2024-004: Student Financial Audit Cluster - Special Tests and Provisions: Disbursements to or on Behalf of Students (Significant Deficiency) Corrective Action: Casper College’s award notifications have been updated to include when funds will be disbursed. In addition, the award notifications refere...
2024-004: Student Financial Audit Cluster - Special Tests and Provisions: Disbursements to or on Behalf of Students (Significant Deficiency) Corrective Action: Casper College’s award notifications have been updated to include when funds will be disbursed. In addition, the award notifications reference the Important Dates URL on the Casper College website for parents and students to refer to that include award disbursement dates. Anticipated Completion Date: 9/6/2024 Contact Person: Laurie Johnstone
Finding 2024-002 - Significant Deficiency: Enrollment Reporting Condition For 1 of 17 students tested, the student’s status was reported incorrectly to the National Student Loan Data System (NSLDS). The student graduated however was reported to NSLDS as withdrawn. The student’s status was also repor...
Finding 2024-002 - Significant Deficiency: Enrollment Reporting Condition For 1 of 17 students tested, the student’s status was reported incorrectly to the National Student Loan Data System (NSLDS). The student graduated however was reported to NSLDS as withdrawn. The student’s status was also reported late, after 60 days. In addition, another student’s status was also reported late. The sample was not a statistically valid sample. Corrective Action Plan The school agrees with the finding. While the withdrawn status was reported for this specific student, the follow-up graduated status was not. This student completed the graduation requirements much later. The school has implemented improved communication between registrar and financial aid to be sure these later graduations are reported. In addition, the timeframe for sending monthly enrollment reports through the National Student Clearinghouse will be altered to improve timely reporting of all statuses. The late statuses were by only a few days and should be resolved by adjusting this timeline. Name(s) of Contact Person(s) Responsible for Corrective Action: Jeff Aalbers Anticipated Completion Date: January 31, 2025
Finding 2024-001 - Eligibility Condition For 1 out of 7 students tested, the school disbursed a loan to a student that had a Perkins student loan in default and there was no support documenting that the student was not in default at the time of the disbursement. The sample was not a statistically va...
Finding 2024-001 - Eligibility Condition For 1 out of 7 students tested, the school disbursed a loan to a student that had a Perkins student loan in default and there was no support documenting that the student was not in default at the time of the disbursement. The sample was not a statistically valid sample. Corrective Action Plan The school agrees with the finding. Procedures have been updated to ensure all verification and c-code reviews are conducted prior to disbursing of any Title IV aid. This would include maintaining documentation of clearance that is recent and up-to-date in the student’s permanent online folder. Name(s) of Contact Person(s) Responsible for Corrective Action: Jeff Aalbers Anticipated Completion Date: January 31, 2025
View Audit 336383 Questioned Costs: $1
Finding 518009 (2024-001)
Significant Deficiency 2024
Finding2024-001: FEDERAL WORK STUDY-WORKING DURING CLASS TIME Comments on Finding and Recommendation(s): We concur with this finding. Due to the error rate of FWS instances of noncompliance, the Institution should review and update its internal controls related to FWS to ensure that students are not...
Finding2024-001: FEDERAL WORK STUDY-WORKING DURING CLASS TIME Comments on Finding and Recommendation(s): We concur with this finding. Due to the error rate of FWS instances of noncompliance, the Institution should review and update its internal controls related to FWS to ensure that students are not working during scheduled class time and enhance communication between Federal Work Study supervisors and registration department to ensure instances of noncompliance do not recur. Action Taken or Planned: 1} The school IT department is setting up the WorkEasy clock in/clock out system for students to lock students out of being able to clock in during scheduled class times. 2} Supervisors will examine each time card to verify no student has worked during scheduled class hours unless as defined in Volume 6 Chapter 2: Working During Scheduled Class Time Prohibited - "Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented." Documentation will be provided before the work is approved to be classified and paid as FWS wages earned. 3} Supervisors will be trained and required to sign a policy at the beginning of each award year or upon hire that states students are not permitted to work during scheduled class hours unless they meet one of the documented exceptions in Volume 6 Chapter 2. By signing this policy, supervisors agree that they may be subject to disciplinary action if they fail to abide this policy.
Non-Compliance with Monthly Direct Loan Reconciliations Management agrees with the finding and the auditor's recommendation. Mass General Brigham (MGB) will update existing procedures to include a formal monthly Direct Loan reconciliation with applicable supporting documentation. This will be implem...
Non-Compliance with Monthly Direct Loan Reconciliations Management agrees with the finding and the auditor's recommendation. Mass General Brigham (MGB) will update existing procedures to include a formal monthly Direct Loan reconciliation with applicable supporting documentation. This will be implemented February 2025 for the period beginning January 2025. Updates will be prepared by the Director of Student Financial Aid and the Director of Finance for review and approval by the Controller's Office prior to implementation.
2024-001 – Student Financial Assistance Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education ...
2024-001 – Student Financial Assistance Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 – Year Ended June 30, 2024 Criteria: Institutions shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in § 314.4 and shall be reasonably designed to achieve the objectives of this part, as set forth in the objectives of section 501(b) of the Act (16 CFR 314.3(a)). Base your information security program on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks (16 CFR 314.4(b)). Condition: The College did not implement a written information security program and a risk assessment as part of the Gramm-Leach-Bliley Act’s (GLBA) standards for safeguarding customer information. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. Corrective Action Plan: We are currently working with our IT vendors (CampusWorks and Lockstep) on policies and increasing GLBA compliance. Responsible Person for Corrective Action Plan: Holly Tharp, Vice President for Finance and Business Implementation Date for Corrective Action Plan: June 30, 2025
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPN’s are retained for at least three years after payment in accordance with the federal regulation. Explanation of disa...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPN’s are retained for at least three years after payment in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Item was in reference to Perkins Loans that were assigned to ED. While the University does not disagree with the fact that three MPN’s were unavailable, each were old Perkins Loans, and each were successfully assigned to ED utilizing alternative documentation, as suggested by ED. The University has a current process in place to retain all information in student files for a minimum of three years. Name(s) of the contact person(s) responsible for corrective action: Mark Freed Planned completion date for corrective action plan: 06/30/2025
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: T...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This process is being reviewed with the Registrar’s Office, as they complete enrollment reporting through the Clearinghouse. The University has found that some delays are happening due to the lack of federal aid at the initial time. For example, one student started in Fall 2023 and the University has documentation to reflect the student was reported to Clearinghouse within the required timeframe. However, the student had not completed Entrance Counseling or a Master Promissory Note, thus they had not received Title IV aid and were not included in the request file from NSLDS to the Clearinghouse. The University will continue to review and make appropriate changes to the current process. Name(s) of the contact person(s) responsible for corrective action: Mark Freed Planned completion date for corrective action plan: 06/30/2025
Planned Corrective Action: The Organization has implemented several measures to enhance its student attendance tracking and withdrawal processes to ensure compliance with federal regulations as of April 2024. Key corrective actions include: 1. Student Attendance Warning (SAW) Forms: Instructors will...
Planned Corrective Action: The Organization has implemented several measures to enhance its student attendance tracking and withdrawal processes to ensure compliance with federal regulations as of April 2024. Key corrective actions include: 1. Student Attendance Warning (SAW) Forms: Instructors will issue a SAW form to any student accumulating four unexcused absences. This form serves as notification that the student may be withdrawn from the class after eight unexcused absences. Signed SAW forms will be submitted to the Registrar to improve documentation and tracking. 2. Bi-Weekly Attendance Review: The Registrar and Financial Aid Counselor will meet bi-weekly to review attendance records and ensure that proper documentation (including SAW forms) is on file for all students with unexcused absences. Instructors will be promptly notified to address any missing documentation. 3. Withdrawal Process and R2T4 Completion: Withdrawn students will receive timely email notifications, and R2T4 forms will be completed on the same day of the withdrawal notification. These forms will be reviewed by the third-party processor, FAME, to ensure accuracy. Funds will be returned via AFA within three business days of the R2T4 review. 4. Monitoring and Compliance: Regular audits will be performed to ensure adherence to this corrective action plan. Ongoing training will be provided to all responsible parties, including Student Services, Admissions, Instructors, the Registrar, and Financial Aid staff, to maintain compliance with attendance tracking and withdrawal processes. Anticipation Date of Completion: Corrective action steps are currently in place, and monitoring is ongoing. Bi-weekly attendance reviews and audits are scheduled moving forward. R2T4 processing improvements are effective immediately.
View Audit 336193 Questioned Costs: $1
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