Corrective Action Plans

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National Student Loan Data System (NSLDS) Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”. Explanation of disagreement with audit finding: There is no disagr...
National Student Loan Data System (NSLDS) Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Although the Colleague data is correct, the logic in Colleague used to send the files to the NSC is excluding records when the student is not registered for classes in the month an action such as graduation or withdrawal occurs. In that situation the NSC is inserting default dates onto the record based on the last date of their classes in the prior term. We are working with our IT team & Ellucian on an approach to update that logic. In the meantime, we will implement a reporting solution to allow manual correction of these issues. Name of the contact person responsible for corrective action: Kris Ragozzino, Registrar Planned completion date for corrective action plan: Already in place.
Finding 523967 (2024-001)
Significant Deficiency 2024
Finding 2024-001 Condition Condition: The change in student status for 25 of the 25 students tested was not reported to the National Student Loan Data Systems (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, these students were ultimately reported to the N...
Finding 2024-001 Condition Condition: The change in student status for 25 of the 25 students tested was not reported to the National Student Loan Data Systems (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, these students were ultimately reported to the NSLDS. Corrective Action Plan The Director of Student Financial Services and the Registrar resolved the issue that caused delayed enrollment changes being submitted to NSLDS due to turnover. The Office of the Registrar identified the errors in the National Student Clearinghouse reporting. They worked internally with our IT department to pinpoint the errors resulting in delays in submission to the National Student Loan Database Systems (NSLDS) via the National Student Clearinghouse. The Office of the Registrar submitted overdue files to the National Clearinghouse in conjunction with the Senior Director of Information Technology to ensure all technical requirements are met. These updates and alignments should bring late reporting to zero. As of January 2025, all prior term file submissions have been submitted to the National Student Clearinghouse. Name of Contact Person Responsible for Corrective Action: Elizabeth Brentzel Anticipated Completion Date: Winter 2025
Finding 2024-004 Student Financial Aid Cluster, CFDA # 84.063, 84.268 Condition: The College did not report the actual disbursement date that students receive the Direct Loan and/or Pell Funds to the COD system. Corrective Action Plan: ...
Finding 2024-004 Student Financial Aid Cluster, CFDA # 84.063, 84.268 Condition: The College did not report the actual disbursement date that students receive the Direct Loan and/or Pell Funds to the COD system. Corrective Action Plan: Objective: To ensure the Financial Aid office reports the actual disbursement date the student receives the Direct Loan and/or Pell funds to the COD system. Corrective Actions: 1. Establish a Standard Operating Procedure (SOP) for reporting disbursement dates 2. Implement an automated system for disbursement reporting 3. Training for Financial Aid and Accounting staff 4. Coordination between relevant departments 5. Verification and reconciliation process 6. Review and monitor data submissions 7. Establish a process for correcting disbursement errors 8. Ongoing monitoring and follow-up Monitoring and Follow-Up: The Financial Aid Office will be responsible for ensuring the implementation of this corrective action plan and will provide monthly updates to senior management. Person(s) Responsible for Corrective Action Plan: Jamieta Hoskins, Director of Financial Aid Anticipated Completion Date for Corrective Action Plan: March 31, 2025
Finding 2024-002 Student Financial Aid Cluster, Assistance Listing # 84.063, 84.268 Condition: The College did not send changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Corrective Action ...
Finding 2024-002 Student Financial Aid Cluster, Assistance Listing # 84.063, 84.268 Condition: The College did not send changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Corrective Action Plan: Objective: To ensure the timely reporting of changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled, to the National Student Loan Data Center (NSLDS) within 60 days of the change. Corrective Actions: 1. Review and update internal policies and procedures 2. Training and education for relevant staff 3. Implement a tracking and monitoring system 4. Conduct regular audits and monitoring 5. Collaborate with NSLDS for support and guidance Monitoring and Follow-Up: • The College’s Financial Aid Office will track the implementation of this Corrective Action Plan and provide monthly progress updates to senior management. • The College will conduct periodic reviews and evaluations to ensure that the plan’s objectives are being met and that the institution remains in full compliance with the Department of Education’s reporting requirements. Person(s) Responsible for Corrective Action Plan: Jamieta Hoskins, Director of Financial Aid Anticipated Completion Date for Corrective Action Plan: February 28, 2025
Management concurs with the finding and the auditor's recommendation to make timely calculations to determine if a refund of Title IV funds is required when a student withdraws. The return of Title IV funds to the U.S. Department were made, but not within the required 45 days. The Seminary has rev...
Management concurs with the finding and the auditor's recommendation to make timely calculations to determine if a refund of Title IV funds is required when a student withdraws. The return of Title IV funds to the U.S. Department were made, but not within the required 45 days. The Seminary has reviewed our procedures to prevent future late returns of Title IV funds. The return of Title IV funds was resolved as June 30, 2024. The Seminary is continuing to review our processes for the return of Title IV funds. We have established procedures to notify the person(s) responsible for calculating if a reunds needs to be made and another person to oversee the process, review the calculation and make sure the funds are returned in a timely manner.
View Audit 343080 Questioned Costs: $1
To address the discrepancies, TVCC has taken the following actions: 1. Properly updated the enrollment status of each of the three (3) identified students in the National Student Clearinghouse (NSC) via NSC’s “Student Lookup” tool. 2. Identified and implemented a mechanism to correct the enrollment...
To address the discrepancies, TVCC has taken the following actions: 1. Properly updated the enrollment status of each of the three (3) identified students in the National Student Clearinghouse (NSC) via NSC’s “Student Lookup” tool. 2. Identified and implemented a mechanism to correct the enrollment status issues caused by CPCC issuance. 3. Assigned a dedicated NSC staff member to process enrollment report submissions and resolve errors. 4. The Registrar’s Office and Financial Aid Office , in collaboration with the Enterprise Systems Support Analyst, are implementing an internal audit tool to better screen enrollment and graduate reports before submission to NSC.
Management agrees with the finding. The College has controls in place to ensure proper and timely reporting to the third-party service provider. The exceptions included above reflected incorrect enrollment statuses on the Banner report due to unofficial withdrawals by the students. The College is c...
Management agrees with the finding. The College has controls in place to ensure proper and timely reporting to the third-party service provider. The exceptions included above reflected incorrect enrollment statuses on the Banner report due to unofficial withdrawals by the students. The College is currently working with their third-party service provider and the Alabama Community College System (ACCS) to ensure the enrollment status of the students is properly reflected on the Banner reports moving forward. We are currently working with ACCS and the National Student Clearinghouse (NSC) to ensure the statuses of the students are reported correctly. 1)The end of term enrollment status reporting process will be ran after the unofficial withdrawals have been completed. 2) The Banner report will be reviewed for accuracy to ensure the unofficially withdrawn students have the correct enrollment status. 3)All Banner reports sent to NSC will be kept on the shared drive to document timely reporting along with the dates reported. 4) All NSC error reports will be downloaded to document the timely review of errors.
The College will have the Director of Financial Aid to send the post-withdrawal letter the same day as performing the return of funds calculations which will be well within the 45 day requirement. If a post-withdrawal letter is to be sent, it will be recorded and logged on the same spreadsheet the F...
The College will have the Director of Financial Aid to send the post-withdrawal letter the same day as performing the return of funds calculations which will be well within the 45 day requirement. If a post-withdrawal letter is to be sent, it will be recorded and logged on the same spreadsheet the Financial Aid Office tracks withdrawals. Completion date: 2/15/2025. Responsible staff: Crystal Hamilton, Director of Financial Aid
The College has reviewed it’s policies and procedures related to return of funds calculations. When a student wants to withdraw from the College, the student will complete an online withdrawal form. Once the form is completed, an electronic copy of the form is sent to several offices, Financial Aid ...
The College has reviewed it’s policies and procedures related to return of funds calculations. When a student wants to withdraw from the College, the student will complete an online withdrawal form. Once the form is completed, an electronic copy of the form is sent to several offices, Financial Aid being included. The Financial Aid Office will use the date on the electronic withdraw form in the Return of Title IV calculation. Completion date: 2/15/2025. Responsible staff: Crystal Hamilton, Director of Financial Aid
View Audit 342864 Questioned Costs: $1
The College is not an attendance taking school and will not be using last date attended, but the College has implemented procedure to use the last date of an academic activity as standard for a non-attendance taking school. At the end of each semester, the College has put a procedure in place to rev...
The College is not an attendance taking school and will not be using last date attended, but the College has implemented procedure to use the last date of an academic activity as standard for a non-attendance taking school. At the end of each semester, the College has put a procedure in place to review all grades within 7 business days of final grades being reported. Once reviewed, the Director of Financial Aid will send an email to all faculty for the student to request that last date of an academic activity for on-ground students. For online students, the Director of Online Learning will provide the last date an academic activity recorded in the online platform. Once the last date of academic activity has been provided to the Financial Aid Office, that date will be used in the return of funds calculation. The College will process all return of funds calculations before the standard 45 day timeframe. Completion date: 2/15/2025. Responsible staff: Crystal Hamilton, Director of Financial Aid
View Audit 342864 Questioned Costs: $1
The Registrar’s Office will review the enrollment roster before the information is uploaded to National Student Clearinghouse and will do a second a review of the report that the National Student Clearinghouse will populate upon processing the enrollment roster. The Registrar’s Office will send enro...
The Registrar’s Office will review the enrollment roster before the information is uploaded to National Student Clearinghouse and will do a second a review of the report that the National Student Clearinghouse will populate upon processing the enrollment roster. The Registrar’s Office will send enrollment rosters every 30 days to the National Student Clearinghouse (NSC). Graduate roster will be sent to the National Student Clearinghouse within 60 days of degree completion. National Student Clearinghouse will then send the information to NSLDS for the information in NSLDS to be updated. Completion date 2/15/2025. Responsible staff: Margaret Smith, Registrar
The Director of Financial aid will update the procedure to include a report to be reviewed of credits earned to verify the amounts to be disbursed to the student is in compliance standards of the correct grade level for Direct Loans. All financial aid staff will be updated on procedures to review th...
The Director of Financial aid will update the procedure to include a report to be reviewed of credits earned to verify the amounts to be disbursed to the student is in compliance standards of the correct grade level for Direct Loans. All financial aid staff will be updated on procedures to review the Direct Loan amounts to credits earned when packaging the student and a final approval from either the Assistant Director of Financial Aid or the Director of Financial Aid before the award letter is sent to the student. Completion date 2/15/2025. Responsible staff: Crystal Hamilton, Director of Financial Aid
View Audit 342864 Questioned Costs: $1
The Director of Financial Aid will review and verify the funds that were disbursed to the students account match the disbursement dates in COD on the date the transfer batch report is sent to the College’s Business Office. Completion date: 2/15/2025. Responsible staff: Crystal Hamilton, Director of ...
The Director of Financial Aid will review and verify the funds that were disbursed to the students account match the disbursement dates in COD on the date the transfer batch report is sent to the College’s Business Office. Completion date: 2/15/2025. Responsible staff: Crystal Hamilton, Director of Financial Aid
The disbursement letter that we previously had notified they had the right to decline their loan. As with the recommendation of our auditor, the letter’s wording has already been changed from the right to decline their loan to the right to cancel their loan by the Director of Financial Aid. Letter a...
The disbursement letter that we previously had notified they had the right to decline their loan. As with the recommendation of our auditor, the letter’s wording has already been changed from the right to decline their loan to the right to cancel their loan by the Director of Financial Aid. Letter also states that the request must be received by KWC within 14 days of the date on the notice. Completion date: 9/1/2024. Responsible staff: Crystal Hamilton, Director of Financial Aid
Views of responsible officials and planned corrective actions - Northwestern Oklahoma State University agrees with the auditor's findings and recommendations. Upon review, the status changes were submitted to the Clearinghouse within the mandatory time frame; however, the Clearinghouse database did...
Views of responsible officials and planned corrective actions - Northwestern Oklahoma State University agrees with the auditor's findings and recommendations. Upon review, the status changes were submitted to the Clearinghouse within the mandatory time frame; however, the Clearinghouse database did not reflect the updates. University management will communicate with the Clearinghouse to try and resolve any conflicts with data uploads causing the errors.
Views of responsible officials and planned corrective actions - Northwestern Oklahoma State University agrees with the auditor's findings and recommendations. The University corrected the software perimeters to correctly reflect the number of days for breaks and to also reflect calculations involvi...
Views of responsible officials and planned corrective actions - Northwestern Oklahoma State University agrees with the auditor's findings and recommendations. The University corrected the software perimeters to correctly reflect the number of days for breaks and to also reflect calculations involving institutionally match FSEOG funds that were not required for FY25. Management will continue to monitor adherence to Title IV rules and regulations.
View Audit 342631 Questioned Costs: $1
2024-003 – Student Financial Assistance Cluster – Special Tests and Provisions – NSLDS Enrollment Reporting Condition During testing, it was determined that 31 of the 60 students tested for enrollment status changes had missing status changes, late certification dates, or incorrect information refle...
2024-003 – Student Financial Assistance Cluster – Special Tests and Provisions – NSLDS Enrollment Reporting Condition During testing, it was determined that 31 of the 60 students tested for enrollment status changes had missing status changes, late certification dates, or incorrect information reflected within their NSLDS reporting. Recommendation We recommend that the College review its control policies to ensure that reporting is completed accurately and timely. Wherever possible, any technological errors discovered should be pursued with the responsible party in order to try to determine a cause, and a solution or preventative measure should be implemented to prevent future errors from occurring. Comments on the Finding Management is aware of the oversight and will ensure that there are processes in place for this to be improved upon. Actions Taken By June of 2025, the National Student Clearinghouse reporting responsibility will be transferred to the Financial Aid Office. The employee taking on the responsibility will undergo training with the Clearinghouse and will work with the College’s Office of Assessment and Research to ensure that all parameters are set up correctly within Banner to ensure that reported information pulls correctly from the software.
Management’s Response: Management understands the importance of ensuring information is reported accurately and timely and the requirement to report to the NSLDS the enrollment status of students who receive federal funds. The College will review its controls and procedures to ensure that not only a...
Management’s Response: Management understands the importance of ensuring information is reported accurately and timely and the requirement to report to the NSLDS the enrollment status of students who receive federal funds. The College will review its controls and procedures to ensure that not only are status changes reported to the Clearinghouse, but also that the enrollment changes are reported appropriately from the National Student Clearinghouse to NSLDS. Views of Responsible Officials and Corrective Action: We will reassess controls, review these processes and implement controls, including multiple layers of review, to ensure that timely and accurate enrollment reporting is made. Furthermore, the reporting data was appropriately updated subsequent to the required timeframe. Name of Responsible Person: Melissa Creasy, Director of Student Financial Aid Implementation Date: Immediately
Management’s Response: Management understands the requirements specific to calculating and returning unearned Title IV aid. Management acknowledges and agrees with the findings as presented. Views of Responsible Officials and Corrective Action: We will reassess controls, review these processes and ...
Management’s Response: Management understands the requirements specific to calculating and returning unearned Title IV aid. Management acknowledges and agrees with the findings as presented. Views of Responsible Officials and Corrective Action: We will reassess controls, review these processes and implement controls to ensure that timely calculations and return of funds are made. Furthermore, the funds noted were sent back prior to year-end. Name of Responsible Person: Melissa Creasy, Director of Student Financial Aid Implementation Date: Immediately
Corrective Action Planned: The Financial Aid Office will employ a two person process for reviewing R2T4s. The Asst. VP of Financial Aid will perform the R2T4 and the Associate Director will double check the results once per week. Any funds needing to be returned will be done within 5 business days o...
Corrective Action Planned: The Financial Aid Office will employ a two person process for reviewing R2T4s. The Asst. VP of Financial Aid will perform the R2T4 and the Associate Director will double check the results once per week. Any funds needing to be returned will be done within 5 business days of completion of the R2T4 calculation. Name(s) of Contact Person(s) Responsible for Corrective Action: Paula Lehrberger, Asst. VP of Financial Aid and Wendy Kern, Associate Director of Financial Aid. Anticipated Completion Date: {January 1, 2025
Finding No. 2024-002 - Internal Controls over Student Financial Assistance Special Tests and Provisions Condition: • During the compliance testing of “Special Tests and Provisions – Return of Funds” we noted that fourteen (14) return of funds calculations for the spring semester did not use the corr...
Finding No. 2024-002 - Internal Controls over Student Financial Assistance Special Tests and Provisions Condition: • During the compliance testing of “Special Tests and Provisions – Return of Funds” we noted that fourteen (14) return of funds calculations for the spring semester did not use the correct dates. • During the audit of the Federal Student Assistance Cluster, we noted one (1) instance the income tax reported on the Institutional Information Record (ISIR) did not match the information on the student’s income tax transcript. We also noted one (1) instance of the student’s household size not agreeing to the ISIR. Plan: • For the Return of Funds, this process was calculated by the PowerFAIDs system. The system did not consider the correct dates for spring break. RLC has moved to the Colleague system and the dates have been verified. • (1) For the verification area, one student’s AGI was reported using the wrong line of the tax return resulting in an understatement of AGI. This was a human error and did not result in a change in the student’s EFC. The specialist was told about the error and will pay closer attention to the numbers. (2) For the student with the household size, the student did not include all in the household on the verification worksheet. Due to the conflict, the student was contacted for the correct information. This information was received in writing and updated. However, the correct verbiage was not used. From that day forward, a student will be required to complete a new verification worksheet with the exact verbiage required. Anticipated Date of Completion: Immediately upon learning of the deficiencies. Contact Person Responsible for Corrective Action: Amy Epplin, Director of Institutional Compliance & Research
Corrective Action Plan: The College has started to run the RRREXIT job along with creation and mailing process of Federal Director Student Loan exit counseling letters biweekly. The College is working with a consulting firm to automate the process so that scheduling software will be used to kick off...
Corrective Action Plan: The College has started to run the RRREXIT job along with creation and mailing process of Federal Director Student Loan exit counseling letters biweekly. The College is working with a consulting firm to automate the process so that scheduling software will be used to kick off and complete the process entirely. The College will receive an email notification that it was completed successfully. A different staff member will be designated to oversee the process to ensure that the letters are generated and mailed biweekly. The College is developing a Question & Answer process to review different areas of the financial aid process to make sure the College is in compliance. Timeline for Implementation of Corrective Action Plan: Present Contact Person Kimberly Tibbetts, Director of Financial Aid
Corrective Action Plan: The finding was due to administrative error when a staff member failed to manually input the correct student’s Pell award after the calculation was reviewed. The College has corrected the error and returned the $128 Pell funds back to the U.S. Department of Education. The Col...
Corrective Action Plan: The finding was due to administrative error when a staff member failed to manually input the correct student’s Pell award after the calculation was reviewed. The College has corrected the error and returned the $128 Pell funds back to the U.S. Department of Education. The College has reviewed all manually calculated and inputted Pell funds disbursed in the 2024 fiscal year noting no other discrepancies. Timeline for Implementation of Corrective Action Plan: Present Contact Person Kimberly Tibbetts, Director of Financial Aid
View Audit 342189 Questioned Costs: $1
Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following are the findings as noted in the Bay Mills Community College Single Audit report for the year ended June 30, 2024, and corrective actions to be completed. 2024-001 – Status Change Reporting Issues. Au...
Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following are the findings as noted in the Bay Mills Community College Single Audit report for the year ended June 30, 2024, and corrective actions to be completed. 2024-001 – Status Change Reporting Issues. Auditor Description of Condition and Effect. During our testing of the Pell Grant program, we selected a sample of forty students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). Of the forty tested, nine were out of compliance based on the criteria outlined in the Department of Education's Code of Federal Regulations at 34 CFR 690.83(b)(2). As a result of this condition, the NSLDS system may not be updated with correct student information, which may cause subsequent awarding issues or loan repayment discrepancies. Auditor Recommendation. We recommend that the College establish a withdrawal policy to improve the accuracy of status change reporting. We also recommend enhanced processes for reviewing and verifying the accuracy of data submissions to NSLDS. Corrective Action. The College has implemented an Administrative Withdrawal Policy, approved by the Board of Regents on November 15, 2024. This policy will enhance the identification and reporting of students who cease attending classes. Additionally, the College will receive a Roster Response file from the National Student Clearinghouse, containing the full dataset sent to NSLDS, which will be reviewed for accuracy. Responsible Person. Katie Corbiere, Director of Financial Aid. Anticipated Completion Date. June 30, 2025
Finding 522702 (2024-001)
Significant Deficiency 2024
Webster University is in the midst of an enterprise system implementation, set to go live, June 2025, which will provide the institution with better tools with which to detect and update enrollment reporting discrepancies in a timely manner. Additionally, recently the enrollment reporting responsibi...
Webster University is in the midst of an enterprise system implementation, set to go live, June 2025, which will provide the institution with better tools with which to detect and update enrollment reporting discrepancies in a timely manner. Additionally, recently the enrollment reporting responsibilities have been transitioned to a more tenured member of the Registrar team, who is knowledgeable about enrollment reporting and understands its nuances and challenges and is positioned to be more successful in identifying and resolving discrepancies going forward. The Registrar’s Office, who is responsible for enrollment reporting, has also agreed to a system of monthly internal auditing processes so that there are more frequent and reliable checks to compare institutional data against NSLDS data for accuracy.
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