Corrective Action Plans

Finding 1204835 (2025-003)

Material Weakness 2025

MD

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

FINDING 2025-003 Name of Responsible Individual: Brandon Rhone, Systems Administrator Corrective Action: We implemented a process which assigns communications management codes based on transmittal activity of each federal direct loan. On the same day a loan is disbursed, our system applies the appro...

FINDING 2025-003 Name of Responsible Individual: Brandon Rhone, Systems Administrator Corrective Action: We implemented a process which assigns communications management codes based on transmittal activity of each federal direct loan. On the same day a loan is disbursed, our system applies the appropriate code to the student record. These codes are then automatically selected for the correct loan disbursement notification to be sent either to the student or parent based on the federal loan type. Anticipated Completion Date: Already completed

View Audit 396468

Finding 1204834 (2025-002)

Material Weakness 2025

Stevenson University, Inc.

MD

Internal Control / Segregation of Duties Student Financial Aid Reporting

FINDING 2025-002 Name of Responsible Individual: Chad Wick, Director of Financial Aid Corrective Action: We have implemented a new Quality Assurance Measure for Auditing all students selected for verification. The process begins with the FA advisor team. They are responsible for ensuring all documen...

FINDING 2025-002 Name of Responsible Individual: Chad Wick, Director of Financial Aid Corrective Action: We have implemented a new Quality Assurance Measure for Auditing all students selected for verification. The process begins with the FA advisor team. They are responsible for ensuring all documents have been received and verification has been completed. In Colleague the advisor will then mark the file is ready for audit. Chad Wick, Director, Financial aid or Brandon Rhone, Systems Administrator, will review all documents and verification steps and then update the verification status to verified and the communication code to audited. Anticipated Completion Date: Already completed

View Audit 396468

Finding 1204830 (2025-001)

Material Weakness 2025

Stevenson University, Inc.

MD

Cash Management Student Financial Aid

FINDING 2025-001 Name of Responsible Individual: Mary Beth Schiller-Schwenke, Chief Financial Officer and Controller Corrective Action: The Federal Pell Grant Program instances resulted from reversals of student awards. The Business Office routinely monitors the general ledger for award transactions...

FINDING 2025-001 Name of Responsible Individual: Mary Beth Schiller-Schwenke, Chief Financial Officer and Controller Corrective Action: The Federal Pell Grant Program instances resulted from reversals of student awards. The Business Office routinely monitors the general ledger for award transactions, however, reversals of student aid awarded late in the academic term can be missed. The Financial Aid Office will be responsible for notifying the Business Office when they initiate award reversals that necessitate a refund. The Business Office has updated procedures so that the related general ledger accounts are reviewed no less than once per week for the full year. In addition to ongoing monitoring of the related general ledger accounts, the Business Office will also create automated reporting to notify staff of the pending account balances. Anticipated Completion Date: April 30, 2026

View Audit 396468

Finding 1204820 (2025-008)

Material Weakness 2025

Urshan College

MO

Cash Management Matching / Level of Effort / Earmarking Student Financial Aid § 200.303

2025-008 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University should implement formal review procedures to document that the Cash Management reconciliation and drawdown reviews are bei...

2025-008 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University should implement formal review procedures to document that the Cash Management reconciliation and drawdown reviews are being performed to correct errors in a timely manner and to minimize the likelihood of errors going undetected. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University performs cash management reconciliation and drawdown reviews; however, formal documentation of these reviews has not been consistently maintained. To address this, the University is implementing formal review procedures that include documented evidence of reconciliation and drawdown review activities. As part of this process, reconciliations and drawdowns prepared by FA Solutions will be reviewed by the Financial Aid Office for accuracy and completeness prior to submission and reporting. These procedures will be formalized within a standardized SOP, which will outline review timelines, responsibilities, and required documentation to ensure errors are identified and resolved in a timely manner and to reduce the risk of discrepancies going undetected. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 4/30/2026

View Audit 396458

Finding 1204818 (2025-006)

Material Weakness 2025

Urshan College

MO

Student Financial Aid Eligibility Significant Deficiency § 200.303

2025-006 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are award...

2025-006 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has conducted a review of its procedures for awarding Title IV funds, with particular attention to the awarding of Summer Pell. Through this review, we identified that Summer Pell was not awarded to eligible students during the applicable period, due in part to a misunderstanding of awarding requirements during a transition in third-party processing support. Urshan has since partnered with FA Solutions to strengthen oversight and ensure alignment with federal awarding requirements. Updated procedures have been implemented to ensure all eligible students are properly evaluated for Title IV aid, including Summer Pell, across all applicable terms. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 8/31/2026

View Audit 396458

Finding 1204816 (2025-004)

Material Weakness 2025

Urshan College

MO

Special Tests & Provisions Student Financial Aid Significant Deficiency § 200.303

2025-004 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation o...

2025-004 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Urshan has partnered with FA Solutions, an experienced third-party processor. Through this partnership, we have strengthened our processes and implemented additional checks and balances to ensure that R2T4 determinations are identified, calculated, and processed in a timely and compliant manner. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 3/31/2026

View Audit 396458

Finding 1204815 (2025-003)

Material Weakness 2025

Urshan College

MO

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

U.S. Department of Education 2025-003 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are...

U.S. Department of Education 2025-003 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Urshan is currently in the onboarding process to partner with the National Student Clearinghouse, which will improve the timeliness and accuracy of our enrollment reporting to NSLDS. In addition, we are developing and implementing a standardized SOP that establishes defined reporting schedules (at least every 60 days), clearly outlines roles and responsibilities, and includes reconciliation procedures to ensure data accuracy. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 7/31/2026

View Audit 396458

Finding 1204661 (2025-001)

Material Weakness 2025

Alverno College

WI

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

Condition: Management's review of the enrollment reporting did not detect that 2 student's change status was reported to NSLDS with incorrect information. Corrective Action Planned: The offices of Academic Advising and the Registrar will follow the procedure and process on student withdrawals and st...

Condition: Management's review of the enrollment reporting did not detect that 2 student's change status was reported to NSLDS with incorrect information. Corrective Action Planned: The offices of Academic Advising and the Registrar will follow the procedure and process on student withdrawals and student dismissals and inform the Senior Data Specialist and the Office of Financial Aid to ensure the date of withdrawal or date of dismissal is accurately and consistently recorded according to Alverno policy and to the National Student Loan Data System (NSLDS). Name(s) of Contact Person(s) Responsible for Corrective Action: Kate Tisch, Director -Academic Advising, Jillian Smith, Registrar, Denise Sanders, Senior Data Specialist and Naomi Coe, Director of Financial Aid. Anticipated Completion Date: This corrective action has been established and review of student changes of status are reviewed and reported on timely basis and accurately immediately.

View Audit 396431

Finding 1204632 (2025-001)

Material Weakness 2025

Pacific Union College

CA

Student Financial Aid Special Tests & Provisions

Finding: 2025-001 CFDA #: 84.063 and 84.268 Recommendation: We recommend the College monitor and evaluate the schedule reporting dates to the NSLDS and confirm or modify existing policies, procedures, or processes from timely identification to ensure that status changes can be communicated to the NS...

Finding: 2025-001 CFDA #: 84.063 and 84.268 Recommendation: We recommend the College monitor and evaluate the schedule reporting dates to the NSLDS and confirm or modify existing policies, procedures, or processes from timely identification to ensure that status changes can be communicated to the NSLDS within the regulatory timeframes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding Corrective Action Plan: All graduate and withdrawn student files will be reviewed on a monthly basis to verify any status changes are reported to NSLDS within regulatory timeframes. Training and professional development will be required for responsible staff to ensure a compliance schedule is developed. Personnel will be evaluated to ensure existing policies, procedures, and processes are followed and supported through corrective action where needed. Name of Contact Responsible for Corrective Action: Joy Hirdler, Vice President of Financial Administration, Chief Financial Officer, 707-965-6699 Anticipated Completion Date: March 31, 2026

View Audit 396382

Finding 1203050 (2025-006)

Material Weakness 2025

Connors State College

OK

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation of disagreement with audit finding: There...

Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: One of the findings was a clerical math error. CSC is moving R2T4 Calculations into COD to ensure proper calculations and reporting. The second finding was a date of determination discrepancy. CSC FA and Registrar to review how the last date of academic activity is determined and reported in Banner. The Financial Aid Director to review the R2T4 Process and create an SOP. Name(s) of the contact person(s) responsible for corrective action: Current Financial Aid Director: Tara Torres OR Current Assistant Financial Aid Director: Tina Ballinger Planned completion date for corrective action plan: 06/30/2026

View Audit 396281

Finding 1203046 (2025-005)

Material Weakness 2025

Connors State College

OK

Student Financial Aid Matching / Level of Effort / Earmarking Reporting § 200.303

Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with aud...

Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CSC utilizes National Student Clearinghouse (NSC) for NSLDS Reporting. The Registrar’s office is responsible for Enrollment Reporting. The four students with Reporting discrepancies are correctional students that do not have access to electronic forms. This population of students must submit paper requests and have them physically routed to the Registrar’s office for processing. The Enrollment and Reporting dates were in line; the discrepancy lies in the Program Enrollment date. The Registrar is researching if the student changed programs after their Enrollment dates. For the Enrollment Reporting date discrepancy outside the 60-day requirement, we reported the correct date to NSC. The Registrar has put in a ticket with NSC to see why they reported the Enrollment Date late. Name(s) of the contact person(s) responsible for corrective action: Current Registrar: Tosha Stout and Current Financial Aid Director: Tara Torres Planned completion date for corrective action plan: 6/30/26

View Audit 396281

Finding 1203042 (2025-004)

Material Weakness 2025

Connors State College

OK

Student Financial Aid Eligibility Significant Deficiency § 200.303

Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with fede...

Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The audit finding was a result of a student enrolling in summer coursework, and their awards were not recalculated. CSC is creating a documented Standard Operating Procedure (SOP) on how to package awards prior to each term to prevent under awarding and a Financial Aid Processing Calendar to ensure awarding occurs each term. Name(s) of the contact person(s) responsible for corrective action: Current Financial Aid Director: Tara Torres OR Current Assistant Financial Aid Director: Tina Ballinger Planned completion date for corrective action plan: 06/30/2026

View Audit 396281

Finding 1203038 (2025-003)

Material Weakness 2025

Connors State College

OK

Matching / Level of Effort / Earmarking Student Financial Aid Reporting § 200.303

Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagre...

Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The late reporting was the result of a known FAFSA issue that began occurring with the 24/25 FAFSA Simplification and continues with the 25/26 FAFSA. The exception occurred when the student was not presented with the HS Completion Status question on the application. Students must self-certify they have a HS Diploma or Equivalent to be eligible for Federal Student Aid. CSC exported the origination to COD. COD approved the award, but CSC was unable to post the award to the student’s account because the HS Completion Status was blank. As soon as the student corrected her FAFSA, CSC posted the award and reported it to COD. The CSC FA office now receives a report with missing HS Completion Status each day and deletes federal awards until the issue is resolved preventing late COD Reporting. Name(s) of the contact person(s) responsible for corrective action: Current Financial Aid Director: Tara Torres OR Current Assistant Financial Aid Director: Tina Ballinger Planned completion date for corrective action plan: Completed

View Audit 396281

Finding 1203034 (2025-002)

Material Weakness 2025

Connors State College

OK

Student Financial Aid Allowable Costs / Cost Principles Significant Deficiency § 200.303

Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for calculating and tracking the students employed in community service activities for its Federal Work Study funds to meet the minimum 7% req...

Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for calculating and tracking the students employed in community service activities for its Federal Work Study funds to meet the minimum 7% requirement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CSC is in a rural area that does not afford many community service opportunities and usually files the FWS Community Service Waiver. Personnel changes caused CSC to miss the 24/25 filing deadline. CSC received the 25/26 Waiver on 06/05/2025. The 26/27 Wavier was requested 01/15/2026. CSC is creating a documented Standard Operating Procedure (SOP) on how to request the waiver and creating a Financial Aid Processing Calendar to ensure the deadline is met each year. Name(s) of the contact person(s) responsible for corrective action: Current Financial Aid Director: Tara Torres OR Current Assistant Financial Aid Director: Tina Ballinger Planned completion date for corrective action plan: 06/30/2026

View Audit 396281

Finding 1203019 (2025-003)

Material Weakness 2025

Lake Michigan College

MI

Student Financial Aid Significant Deficiency

Finding Number: 2025-003 Condition: The College did not perform an accurate calculation to determine the amount of funds to return of Title IV funds for 2 students. Planned Corrective Action: Accuracy in performing the required Return to Title IV Funds function is of significant importance to Lake M...

Finding Number: 2025-003 Condition: The College did not perform an accurate calculation to determine the amount of funds to return of Title IV funds for 2 students. Planned Corrective Action: Accuracy in performing the required Return to Title IV Funds function is of significant importance to Lake Michigan College. Currently, a second individual performs an independent review of a sample of calculations. Although we find these two scenarios to be isolated in nature, we will increase our quality control sample review. We are also investigating how we might automate more of the process in order to help reduce any manual error. The two situations noted have been corrected. Contact person responsible for corrective action: Ben Burton, Director of Financial Aid Anticipated Completion Date: 03/15/2026

View Audit 396272

Finding 1203013 (2025-002)

Material Weakness 2025

Lake Michigan College

MI

Student Financial Aid Cash Management Significant Deficiency

Finding Number: 2025-002 Condition: If an institution enters into a Tier One arrangement with a third party servicer, as defined in CFR 668.164(e)(1), the institution must provide to the secretary an up-to-date URL for the contract and contract data, as described in paragraph (e)(2)(vii) of this sec...

Finding Number: 2025-002 Condition: If an institution enters into a Tier One arrangement with a third party servicer, as defined in CFR 668.164(e)(1), the institution must provide to the secretary an up-to-date URL for the contract and contract data, as described in paragraph (e)(2)(vii) of this section for publication in a centralized database accessible to the public. Planned Corrective Action: The URL associated with Lake Michigan’s required disclosure has now been provided to the secretary via the associated Department of Education’s instructions. Contact person responsible for corrective action: Ben Burton, Director of Financial Aid Anticipated Completion Date: 03/19/2026

View Audit 396272

Finding 1203006 (2025-001)

Material Weakness 2025

Lake Michigan College

MI

Student Financial Aid Material Weakness Reporting

Finding Number: 2025-001 Condition: The College did not update the student enrollment information for any of the students graduating in Fall of 2024. Planned Corrective Action: Lake Michigan College understands the significance of accurately reporting student enrollment statuses and will implement e...

Finding Number: 2025-001 Condition: The College did not update the student enrollment information for any of the students graduating in Fall of 2024. Planned Corrective Action: Lake Michigan College understands the significance of accurately reporting student enrollment statuses and will implement enhanced oversight controls. This includes the creation of a log that now documents file “receipts” from the National Student Clearinghouse. These report receipts are then reconciled to file submissions to ensure all files were received. Additionally, we have implemented a more overarching review that ensures all files are adequately processed by the National Clearinghouse. It is important to note the institution has corrected the files noted in the audit finding and all student records have now been updated to reflect accurate graduation and enrollment statuses. Contact person responsible for corrective action: Carrie Beukelman, Registrar Anticipated Completion Date: 03/01/2026

View Audit 396272

Finding 1202974 (2025-001)

Material Weakness 2025

The King's University

TX

Student Financial Aid Special Tests & Provisions

A new Student Information System platform was implemented in the 2024-25 fiscal year. In conjunction with the National Student Clearinghouse the issue was identified, and it was determined that the new system was not tracking the student enrollment status correctly. The issue was resolved in collabo...

A new Student Information System platform was implemented in the 2024-25 fiscal year. In conjunction with the National Student Clearinghouse the issue was identified, and it was determined that the new system was not tracking the student enrollment status correctly. The issue was resolved in collaboration with the Student Information System implementation team and system adjustments were made to ensure accurate and timely reporting.

View Audit 396252

Finding 1202972 (2025-001)

Material Weakness 2025

Southwest Wisconsin Technical College

WI

Student Financial Aid

U.S. Department of Education Southwest Wisconsin Technical College (the District) respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 1, 2024 to June 30, 2025 The findings from the schedule of findings and questioned costs are discussed belo...

U.S. Department of Education Southwest Wisconsin Technical College (the District) respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 1, 2024 to June 30, 2025 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT The audit did not disclose any matters required to be reported in accordance with Government Auditing Standards. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2025-001 Student Financial Assistance Cluster – Assistance Listing No. 84.063 and 84.268 Recommendation: We recommend that the District review its processes and internal controls designed to mitigate the risk of noncompliance with the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Southwest Wisconsin sends enrollment files of all students to the National Student Clearinghouse monthly, who then reports enrollment data to NSLDS. Southwest Tech will continue to work with the Student Information System (SIS) vendor to correct issues in the report used to submit Clearinghouse reports. Southwest Tech will work with the Clearinghouse on discrepancies between the Clearinghouse and NSLDS. Name of the contact person responsible for corrective action: Kelly Kelly, Controller Planned completion date for corrective action plan: June 30, 2026 *** If the U.S Department of Education has questions regarding this plan, please call Kelly Kelly, Controller, at (608) 822-2305.

View Audit 396245

Finding 1202959 (2025-003)

Material Weakness 2025

Felician University

NJ

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

2025-003 – Pell Under-Award Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that a review is implemented to ensure calculations of Pell awards are performed based on the accurate cost of attendance, SAI and enrollment status of the student. Explanation of disa...

2025-003 – Pell Under-Award Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that a review is implemented to ensure calculations of Pell awards are performed based on the accurate cost of attendance, SAI and enrollment status of the student. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the audit review, it was determined that student (ID: 0364337) was under-awarded a Federal Pell Grant due to a manual calculation error. Based on remaining Lifetime Eligibility Used (LEU), the student was eligible for $1,085 but was awarded $627.97. To address this finding, the institution has strengthened internal controls by eliminating manual calculations as a primary method for determining Pell eligibility, implementing a mandatory secondary review prior to disbursement, and requiring verification of LEU through the COD system. In addition, ongoing monthly quality assurance reviews have been established, and staff training has been completed to reinforce compliance with Pell Grant calculation requirements, including Cost of Attendance (COA), Student Aid Index (SAI), and enrollment status. Name(s) of the contact person(s) responsible for corrective action: Kathy Prieto -Executive Director Student Financial Services Planned completion date for corrective action: March 2026.

View Audit 396217

Finding 1202958 (2025-002)

Material Weakness 2025

Felician University

NJ

Student Financial Aid

2025-002 – Title IV Credit Balance Refund Federal Pell Grant Program; Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure any credit balances resul...

2025-002 – Title IV Credit Balance Refund Federal Pell Grant Program; Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure any credit balances resulting from Title IV aid are returned within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has evaluated and strengthened its procedures to ensure compliance with Title IV credit balance regulations (34 CFR §668.165), including the 14-day refund requirement. Enhanced controls include aformalized weekly refund processing schedule, mandatory cross-system verificationbetween Colleague and Business Objects, and comprehensive account-level review priorto disbursement. Additional controls include centralized tracking of refund reports,strengthened approval and documentation requirements, and ongoing system and processreviews to ensure all eligible credit balances are accurately identified and refunded timely.These actions mitigate the risk of delays or omissions and reinforce compliance withfederal requirements. Name(s) of Contact Person(s) Responsible for Corrective Action: Mouhamadou Kane, Sadiailen Companino Torres, Kathy Prieto Planned Completion Date for Corrective Action Plan: March 2026

View Audit 396217

Finding 1202954 (2025-001)

Material Weakness 2025

Felician University

NJ

Student Financial Aid Reporting Significant Deficiency

2025-001 – Enrollment Reporting Federal Pell Grant Program; Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around NSLDS to ensure the University underst...

2025-001 – Enrollment Reporting Federal Pell Grant Program; Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around NSLDS to ensure the University understands the definitions for each enrollment information that gets reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Felician University agrees with the findings and will take the following steps to remedy the issues. First, we will contact the National Student Clearinghouse to evaluate our current reporting structure and make necessary changes to enhance our data output. Secondly, we will revisit our Leave of Absence and Withdrawal policies and procedures to ensure their alignment with NSLDS compliance standards. Management will monitor these issues internally and with periodic engagements with the National Student Clearinghouse during the year to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Nina Hernandez, Director of Registration and Records Planned completion date for corrective action plan: April 30th, 2026

View Audit 396217

Finding 1202952 (2025-003)

Material Weakness 2025

MacCormac College Dba Generations College

IL

Student Financial Aid Reporting

Finding 2025-003 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 ...

Finding 2025-003 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: Management concurs with this finding. The College acknowledges that disbursement dates reported to COD reflected submission dates rather than actual student disbursement dates, resulting in inconsistencies. Corrective actions implemented as follows: 1. Definition Standardization 2. System Configuration & Process Update 1. Actual disbursement dates are captured at the transaction level 2. Data feeds into COD accurately once Financial Aid is converted to Ellucian 3. Reconciliation Controls 1. Monthly reconciliation between: 1. Student account ledger 2. COD system records 4. Quality Assurance Reviews 1. Supervisor approval required prior to COD reporting Timeline: Process corrections implemented in Fall 2025; Full compliance expected by June 30, 2026 Person(s) Responsible for Corrective Action Plan: Anahi Huerta, Director of Financial Aid, Phone: 312-922-1884

View Audit 396203

Finding 1202950 (2025-002)

Material Weakness 2025

MacCormac College Dba Generations College

IL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding 2025-002 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 2025-002 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: Management concurs with this finding. The College did not consistently report student status changes to NSLDS within the required 60-day timeframe due to inefficient tracking processes and system misalignment between internal records and reporting systems. Corrective actions implemented as follows: 1. Automated Tracking & Reporting Calendar 1. Established a compliance calendar with hard deadlines (<30 days internal target) 2. System Integration Improvements 1. Enhanced data alignment between: Ellucian Colleague, National Student Clearinghouse, and NSLDS 3. Accountability Structure 1. Assigned a designated compliance owner for NSLDS reporting 2. Introduced escalation protocols for missed deadlines 4. Monitoring & Reporting 1. Monthly compliance certification to senior leadership Timeline: Process corrections implemented in Summer 2025; Full compliance expected in Fall 2025 onward Person(s) Responsible for Corrective Action Plan: Anahi Huerta, Director of Financial Aid, Phone: 312-922-1884

View Audit 396203

Finding 1202948 (2025-001)

Material Weakness 2025

MacCormac College Dba Generations College

IL

Student Financial Aid Material Weakness Internal Control / Segregation of Duties

Finding 2025-001 Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.063, 84.268 Condition: The College could not timely retrieve all student records and show documentation of reviews and approvals related to student records. Corrective Action Plan: Objective: To ensure the timely...

Finding 2025-001 Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.063, 84.268 Condition: The College could not timely retrieve all student records and show documentation of reviews and approvals related to student records. Corrective Action Plan: Objective: To ensure the timely retrieval of all student records and the proper documentation of reviews and approvals to meet regulatory requirements and to improve accountability in the Student Financial Aid Cluster. Corrective Actions: Management agrees with this finding. The College admits that before Spring 2025, formal documentation for review and approval of financial aid processes, including Return of Title IV (R2T4) calculations, was not consistently kept. Although controls were performed in most cases, the lack of documented evidence for students selected prior to the internal processing improvements prevented demonstrating control effectiveness, which is required under the Uniform Grant Guidance. Corrective actions implemented as follows: 1. Formal SOP Implementation Developed and implemented standardized SOPs for: 1. Financial Aid packaging and disbursement 2. Return of Title IV (R2T4) calculations 3. Review and approval workflows 2. Documentation & Audit Trail Controls 1. Introduced mandatory review/approval checklists for all financial aid transactions 2. Implemented centralized digital storage of supporting documentation 3. Segregation of Duties & Oversight 1. Established defined roles for: Preparer, Reviewer, Final approver. 4. Ongoing Monitoring 1. Monthly internal compliance reviews 2. Quarterly audit-readiness assessments led by senior leadership Timeline: Process corrections implemented in Spring 2025; Full compliance expected by June 30, 2026 Person(s) Responsible for Corrective Action Plan: Anahi Huerta, Director of Financial Aid, Phone: 312-922-1884

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