Corrective Action Plans

Finding 1171099 (2025-002)

Material Weakness 2025

OH

Student Financial Aid Subrecipient Monitoring Reporting

Finding Number: 2025-002 Anticipated Completion Date: 10/07/2025 Responsible Contact Person: Katherine Miranda, University Registrar Kelly Burt, Assistant Registrar Records Management and Reporting Michele Bergman, Assistant Registrar, Records Management and Reporting Planned Corrective Action: The ...

Finding Number: 2025-002 Anticipated Completion Date: 10/07/2025 Responsible Contact Person: Katherine Miranda, University Registrar Kelly Burt, Assistant Registrar Records Management and Reporting Michele Bergman, Assistant Registrar, Records Management and Reporting Planned Corrective Action: The Offices of the Registrar and Admission Operations reviewed the case, reviewed the proper student record protocol, and added a reporting checkpoint to review for dually enrolled students before submitting enrollment reports to the National Student Clearinghouse (NSC). Once NSLDS is updated with NSC data, the Office of the Registrar will work with Office of Financial Aid to confirm NSLDS is accurate for the dually enrolled students.

View Audit 384492

Finding 1170982 (2025-002)

Material Weakness 2025

Maria L. Varisco-Rogers Charter School

NJ

Student Financial Aid Cash Management Internal Control / Segregation of Duties

In response to the findings from the 2025 ACFR, MLVR Charter school will be submitting a CFM CAP to homeroom. The CAP will address the following: 1. Reimbursement requests will be submitted at a minimum quarterly otherwise every two months. 2. Accounting software is updated and reviewed to ensure bu...

In response to the findings from the 2025 ACFR, MLVR Charter school will be submitting a CFM CAP to homeroom. The CAP will address the following: 1. Reimbursement requests will be submitted at a minimum quarterly otherwise every two months. 2. Accounting software is updated and reviewed to ensure budgeted amounts and carryover funds are properly recorded throughout the fiscal year.

View Audit 384380

Finding 1170887 (2025-002)

Material Weakness 2025

Hood College of Frederick, Maryland and Affiliates

MD

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

Corrective Action Plan Finding Number: 2025-002 – Return of Title IV Funds Controls Finding: There is no evidence of a control in place by the College to review Return of Title IV Fund calculations. Corrective Action Planned Given the size of the Financial Aid Office, the College will implement comp...

Corrective Action Plan Finding Number: 2025-002 – Return of Title IV Funds Controls Finding: There is no evidence of a control in place by the College to review Return of Title IV Fund calculations. Corrective Action Planned Given the size of the Financial Aid Office, the College will implement compensating internal controls to ensure R2T4 calculations are accurate, timely, and compliant with federal regulations. Effective immediately, the College will implement the following controls: 1. Standardized R2T4 Processing All R2T4 calculations will be performed using the Department of Education Common Origination & Disbursement (COD) system to ensure consistent application of federal formulas. Official withdrawal dates will be confirmed using Registrar records prior to calculation. 2. Independent Post-Calculation Review Each R2T4 calculation will be reviewed by an individual other than the preparer, where feasible, or through supervisory review when staffing is limited. The review will confirm the accuracy of withdrawal dates, days attended, calculation inputs, and Title IV funds included. 3. Coordination and Reconciliation The Office of Financial Aid will coordinate with Student Accounts to ensure R2T4 results are applied correctly to the student account and that returned funds are processed within required timelines. 4. Documentation and Retention Evidence of review, including reviewer initials and date, will be retained for each R2T4 calculation. A simple R2T4 review checklist or log will be maintained. 5. Ongoing Oversight The Director of Financial Aid will conduct periodic spot checks to ensure R2T4 calculations and reviews are completed accurately and timely. Responsible Official: De Rodrick Jonkins, Director of Financial Aid Anticipated Completion Date: Implemented effective August 1, 2025 Additional Context The Director of Financial Aid assumed the role effective April 1, 2025, after prior corrective actions had been identified. While formal independent review controls were not documented during the audit period, there were no identified R2T4 compliance issues, late returns, or calculation errors. The corrective actions above are intended to formalize review processes and further reduce compliance risk.

View Audit 384186

Finding 1170880 (2025-001)

Material Weakness 2025

Hood College of Frederick, Maryland and Affiliates

MD

Matching / Level of Effort / Earmarking Student Financial Aid Allowable Costs / Cost Principles § 200.303

Corrective Action Plan Finding Number: 2025-001 – Enrollment Reporting Controls – Student Financial Aid Special Test Finding: There is no control in place by the College to review information submitted to NSLDS for student enrollment status changes. Corrective Actions Planned Given the size of the F...

Corrective Action Plan Finding Number: 2025-001 – Enrollment Reporting Controls – Student Financial Aid Special Test Finding: There is no control in place by the College to review information submitted to NSLDS for student enrollment status changes. Corrective Actions Planned Given the size of the Financial Aid Office, the College will implement compensating internal controls to ensure accurate and timely enrollment reporting while maintaining operational efficiency. Effective immediately, the College will implement the following controls: 1. Continued Use of the National Student Clearinghouse (NSC) The College will continue to rely on the National Student Clearinghouse as its third-party servicer for enrollment status reporting to NSLDS. 2. Independent Post-Submission Review On a monthly basis, the Office of Financial Aid will review NSC enrollment reporting confirmation files to verify that enrollment status changes were submitted to NSLDS accurately and within the required 60-day timeframe. This review will be performed by an individual other than the primary preparer, where feasible, or through supervisory review when staffing is limited. 3. Documentation and Retention Evidence of review, including reviewer initials and date, will be retained. A simple enrollment reporting review log will be maintained to document compliance. 4. Ongoing Oversight The Director of Financial Aid will conduct periodic spot checks to confirm controls are operating as intended. Responsible Official: De Rodrick Jonkins, Director of Financial Aid Anticipated Completion Date: February 1, 2026 Additional Context The Director of Financial Aid assumed the role effective April 1, 2025, after prior corrective actions had been initiated. While formal independent review controls were not documented during the audit period, there were no identified instances of late enrollment reporting or inaccurate enrollment status submissions to NSLDS. The corrective actions above are intended to formalize controls and ensure sustained compliance with federal requirements.

View Audit 384186

Finding 1170869 (2025-001)

Material Weakness 2025

Junior College District of East Central Missouri

MO

Student Financial Aid Reporting Significant Deficiency

Janaury 16, 2026 U.S. DEPARTMENT OF EDUCATION East Central College respectfully submits the following corrective action plan for the year ended June 30, 2025. Contact information for the individual responsible for the corrective action: Mr. Chris Hoelzer, Vice President of Finance & Administration E...

Janaury 16, 2026 U.S. DEPARTMENT OF EDUCATION East Central College respectfully submits the following corrective action plan for the year ended June 30, 2025. Contact information for the individual responsible for the corrective action: Mr. Chris Hoelzer, Vice President of Finance & Administration East Central College 1964 Prairie Dell Road Union, MO 63084 Independent public accounting firm: KPM CPAs, PC, 1445 E Republic Rd, Springfield, Missouri 65804 Audit Period: Year Ended June 30, 2025 The finding from the June 30, 2025 audit of the financial statements is below. The finding is numbered with the number assigned in the schedule. FINDING - MAJOR FEDERAL AWARD PROGRAM AUDIT 2025-001 Special Test and Provisions - Return of Title IV Funds Recommendation: We recommend the College implement procedures to strictly comply with the requirements of 34 CFR §668.22 as it relates to calculations of return of Title IV funds. Corrective Action Taken: The college conducted a comprehensive review of all student accounts potentially impacted by the incorrect academic calendar dates and identified 52 students whose Return of Title IV (R2T4) calculations required review. As a result of this reveiw, the Financial Aid Office determined that 41 students required a return of Title IV funds to the U.S. Department of Education. The total amount of funding returned was $12,590. The Financial Aid Office corrected the R2T4 calculations, updated the academic calendar dates in the financial aid system, and processed the required returns of Title IV funds. To prevent recurrence, the College has implemented internal procedures to ensure academic calendar dates are reviewed and verified in the financial aid system before performing R2T4 calculations for each award year. Anticipated Completion Date: Fall semester 2025 and ongoing. Sincerely, Chris Hoelzer Vice President of Finance & Administration

View Audit 384161

Finding 1170859 (2025-001)

Material Weakness 2025

University of Wyoming

WY

Student Financial Aid Subrecipient Monitoring HUD Housing Programs

Views of Responsible Officials and Planned Corrective Actions - The University’s Office of Student Financial Services agrees with the recommendation and will ensure that Return of Title IV (R2T4) calculations and applicable returns of funds for all students who officially or unofficially withdraw ar...

Views of Responsible Officials and Planned Corrective Actions - The University’s Office of Student Financial Services agrees with the recommendation and will ensure that Return of Title IV (R2T4) calculations and applicable returns of funds for all students who officially or unofficially withdraw are completed within required regulatory time frames. To strengthen internal controls related to R2T4 processing, the Office of Student Financial Services under the direction of the Director of Student Financial Services has taken and will continue the following actions: • Reinforce and update R2T4 procedures to clearly document regulatory timelines, roles, and responsibilities, and to include defined ongoing monitoring practices. These updated procedures incorporate periodic review of R2T4 activity to ensure continued compliance. • Enhance the existing internal tracking mechanism to support timely completion of R2T4 calculations and fund returns. This enhancement includes the ability to generate reports that identify upcoming deadlines, completed actions, and any items requiring follow-up. • Provide refresher training to staff within the Office of Student Financial Services and partner offices involved in R2T4 processing, with emphasis on compliance requirements, timelines, documentation standards, and shared accountability across offices. • Incorporate a secondary review process as part of the existing R2T4 procedure. A designated secondary reviewer within the Office of Student Financial Services will confirm the accuracy and timeliness of each R2T4 calculation and associated fund return, with completion of the review documented within the tracking system. These corrective actions will be implemented upon review and approval and will be effective beginning Spring 2026.

View Audit 384150

Finding 1170795 (2025-001)

Material Weakness 2025

Madison Area Technical College District

WI

Student Financial Aid

Student Financial Aid Cluster – Assistance Listing No. 84.063 & 84.268 Recommendation: We recommend that the District design and implement controls over the review of report parameters and enrollment reporting to ensure financial aid software is properly calculate enrollment based on enrolled credit...

Student Financial Aid Cluster – Assistance Listing No. 84.063 & 84.268 Recommendation: We recommend that the District design and implement controls over the review of report parameters and enrollment reporting to ensure financial aid software is properly calculate enrollment based on enrolled credits at the District. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The report builder has been rebuilt, and the enrollment statuses identified have been updated. The District is actively working with NSC to correct statuses for students who were inadvertently impacted in previously submitted files. Name(s) of the contact person(s) responsible for corrective action: Laurie Grigg, Chief Financial Officer Planned completion date for corrective action plan: June 30, 2026

View Audit 384056

Finding 1170762 (2025-001)

Material Weakness 2025

Metropolitan Community College

MO

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring

Enrollment information was not submitted within the required timeframe by the College. Personnel Responsible for Corrective Action: Dena Norris, Associate Vice Chancellor of Student Financial Services, and Tara Dettmer, Director of Financial Aid – Fiscal Operations Anticipated Completion Date: Corre...

Enrollment information was not submitted within the required timeframe by the College. Personnel Responsible for Corrective Action: Dena Norris, Associate Vice Chancellor of Student Financial Services, and Tara Dettmer, Director of Financial Aid – Fiscal Operations Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2026. Views of Responsible Officials and Planned Corrective Action Plan: Despite best efforts by the College to correct the errors in enrollment reporting, the College experienced turnover among staff, and as a result, was unable to shift staffing resources or quickly hire replacement staff to correct the finding. Metropolitan Community College (MCC) is in the process of hiring additional staff dedicated to enrollment and compliance reporting. MCC will make a random selection of 10-15 students each month to verify data was correctly transmitted to National Student Clearinghouse (NSC). A secondary check of these students will be done to ensure the data is also transmitted to the National Student Loan Data System (NSLDS). MCC will also ensure error reports and other data issues are resolved in a timely manner to ensure reporting of students is completed within the regulatory timeframe. Due to the implementation of a new Enterprise Resource Planning system MCC is also validating and correcting any submission errors.

View Audit 383985

Finding 1170758 (2025-002)

Material Weakness 2025

Carl Sandburg College-Community College District 518

IL

Student Financial Aid

Sandburg’s procedures require reviewing and clearing all C codes/comment codes that require resolution. 1. We reviewed the recommendation presented, and we have added language to clearly outline procedures to show the decision-making process and documentation steps, depending on the particular code....

Sandburg’s procedures require reviewing and clearing all C codes/comment codes that require resolution. 1. We reviewed the recommendation presented, and we have added language to clearly outline procedures to show the decision-making process and documentation steps, depending on the particular code. Our procedures for identifying and resolving comment codes are compliant with the recommendations. 2. We have enhanced the workflow to go over the ISIR Code resolution process each year before file review begins. 3. We have added procedures to have the reviewer sign off showing the decision, the reviewer's initials and the date when resolution involves a decision as outlined in the FAFSA specifications guide. 4. Training has been completed by the Director of Financial Aid, Associate Director of Financial Aid. Person(s) Responsible: Dustin Zimmerman, Director of Financial Aid Timing for Implementation: Fall 2025

View Audit 383954

Finding 1170757 (2025-001)

Material Weakness 2025

Carl Sandburg College-Community College District 518

IL

Student Financial Aid Reporting

Sandburg reviewed the audit finding regarding NSLDS reporting. We acknowledge the finding and implemented the following corrective action plan: 1. Added an additional NSLDS report following final grades to ensure we are picking up unofficial withdrawals. 2. Updated our reporting schedule with Cleari...

Sandburg reviewed the audit finding regarding NSLDS reporting. We acknowledge the finding and implemented the following corrective action plan: 1. Added an additional NSLDS report following final grades to ensure we are picking up unofficial withdrawals. 2. Updated our reporting schedule with Clearinghouse/NSLDS. 3. Updated written procedures to include a quality control check before the NLSDS/Clearinghouse file is sent. 4. Added an end-of-term quality control spot check to review that unofficial withdrawal submissions went through. 5. Updated written procedures for NSLDS reporting. Procedures are reviewed as regulations change, as our reporting software evolves, and during staff transitions to ensure compliance. 6. Training completed by the Dean of Enrollment Management, Director of Advising, Registrar, Associate Director of Advising & Transfer Coordination, Director of Financial Aid, Coordinator of Financial Aid, Veterans & Military Services. Procedures are reviewed as regulations change and during staff transitions to ensure compliance. Person(s) Responsible: Angela Snow; Director of Advising, Registrar Timing for Implementation: These procedures were implemented by December 2025.

View Audit 383954

Finding 1170629 (2025-001)

Material Weakness 2025

Otis College of Art and Design

CA

Student Financial Aid Reporting Special Tests & Provisions

November 21, 2025 FINDING 2025-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Otis College of Art and Design agrees with the finding. Upon review of the finding, Financial Aid administration met with Registrar’s staff to create a...

November 21, 2025 FINDING 2025-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Otis College of Art and Design agrees with the finding. Upon review of the finding, Financial Aid administration met with Registrar’s staff to create a new procedure whereby immediate reporting of withdrawals are made directly to NSLDS in addition to the regularly scheduled monthly reports to NSLDS through the National Student Clearinghouse (NSC). This immediate reporting should eliminate any timing issues with the monthly reports through NSC. In addition, a joint effort to streamline the routing of withdrawal forms to the appropriate departments for faster processing is underway. This reprocessing of the withdrawal forms will be implemented in the next 120 days. Responsible Office and Individuals The Executive Director of Financial Aid and The One Stop, Michaela Matsumoto and Registrar, Nicole Raef are the responsible individuals for implementation of the corrective action plan. Corrective Action Plan The Registrar implemented a centralized tracking system that is now used for every withdrawal and graduation status change at all points in the semester. Registration reviews the withdrawal list weekly to ensure each change is accurately reflected in both NSC and NSLDS. To address graduation status updates, we are adjusting the timeline of our final spring enrollment report to NSC so it is submitted at the end of May. This allows NSC to transmit the data to NSLDS at the beginning of June resulting in fewer manual updates in NSLDS. Registration will then review all graduated students to confirm accurate NSLDS reporting rather than relying solely on Clearinghouse submissions. In addition, the Registration office will review and correct the NSC error report on a monthly basis. The Financial Aid and Registration offices will also initiate quarterly meetings to ensure timely submissions and address any emerging issues.

View Audit 383866

Finding 1170557 (2025-002)

Material Weakness 2025

Los Angeles Unified School District

CA

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Student Financial Aid § 200.300 § 200.306 § 200.308 § 200.309 § 200.403

The purpose of the Goods Receipt (GR) is to record receipt of goods or services as soon as they are delivered and verified to be in acceptable condition. A Goods receipt must be posted in SAP for all items actually received. Vendors submit invoice(s) referencing the purchase order (PO) directly to A...

The purpose of the Goods Receipt (GR) is to record receipt of goods or services as soon as they are delivered and verified to be in acceptable condition. A Goods receipt must be posted in SAP for all items actually received. Vendors submit invoice(s) referencing the purchase order (PO) directly to Accounts Payable after delivery, indicating that the goods or services have been provided and requesting payment. Accounts Payable then reviews the vendor invoice, purchase order, and goods receipt in SAP to perform the required three-way match (PO, GR, and vendor invoice) before processing payment. 1. The Accounts Payable team will collaborate with the Procurement Services Division to establish and implement a process that ensures the timely review and reconciliation of Goods Receipt (GR) entries. This will include the development of clear guidance / training materials for schools and offices to periodically review their GR balances. Training will be conducted via Virtual Office Hours on a quarterly basis for sites to make necessary adjustments when the goods or services received differ from the original Purchase Order (PO) or the corresponding invoice. 2. The Accounts Payable team will collaborate with the Procurement Services Division to develop supplemental documentation and guidance regarding proof of delivery for goods and services received. 3. Accounts Payable staff will receive ongoing training throughout the year on documentation and reconciliation requirements, particularly when new internal controls, procedures, and processes are created. Training will be incorporated into regular team meetings, procedural updates, and onboarding for new team members to maintain alignment and accuracy across the department. The implementation target date for the above corrective action plan is June 30, 2026. Name: Rocio Saucedo Title: Director of Accounts Payable Contact Information: Rocio.Saucedo@lausd.net

View Audit 383812

Finding 1170518 (2025-001)

Material Weakness 2025

Northern Kentucky University

KY

Student Financial Aid

Views of responsible officials and planned corrective actions: The University agrees with the auditor's finding and recommendations. The following corrective action will be taken: The University has awarded aid in the amount of $3,729 to students which represents student earned aid from an updated R...

Views of responsible officials and planned corrective actions: The University agrees with the auditor's finding and recommendations. The following corrective action will be taken: The University has awarded aid in the amount of $3,729 to students which represents student earned aid from an updated R2T4 calculation accounting for the proper use of the withdrawal date, institutional charges and total aid for 2024-25 academic year. The University will review, and revise policies and procedures related to the return of funds calculation. Specifically, the University will:  Update procedures to include a review of input items by AVP prior to finalizing returns.  Provide training to relevant staff, including staff outside of the Office of Student Financial Assistance, on proper calculation methods to ensure compliance and accuracy of R2T4 calculations. The University is exploring opportunities to automate partially or completely the R2T4 process to support accurate and efficient processing and enhance compliance.

View Audit 383774

Finding 1170511 (2025-001)

Material Weakness 2025

Huntingdon College

AL

Student Financial Aid

Corrective Action Plan - In order to ensure compliance with 34 CFR 685.309(2) and the 60 day reporting requirement for the students who cease to be enrolled half time by submission of an Intent Not to Return form, as well as, for those students who do not show up for a subsequent semester, the Insti...

Corrective Action Plan - In order to ensure compliance with 34 CFR 685.309(2) and the 60 day reporting requirement for the students who cease to be enrolled half time by submission of an Intent Not to Return form, as well as, for those students who do not show up for a subsequent semester, the Institution has changed the standard reporting transmission date from after the 3rd week of school in the subsequent term to 55 days after the last day of the previous term (approximately the 1st week of the term). This will ensure that all students that haven’t returned will be captured in the required 60 days reporting time. Additionally, we have made the process more user friendly for those involved by changing from script processing to Excel based reporting in an effort to make the data clean in a format that will allow visualization of processing errors. The Registrar will be responsible for ensuring the 60 day reporting requirements are met by setting up the annual transmission dates with clearinghouse for each term of the year by utilizing 55 days between the end of the term as the first reporting for the following period. This reporting requirement will be added to the internal audit completed the Financial Aid Office

View Audit 383713

Finding 1170485 (2025-002)

Material Weakness 2025

Universidad Carlos Albizu, Inc.

PR

Student Financial Aid

Institutional Response The institution concurs with the auditor’s findings and affirms that this was an isolated occurrence. Due to an administrative error, the affected student enrollment reflected a combination of graduate and undergraduate courses. While the withdrawal process was fully executed ...

Institutional Response The institution concurs with the auditor’s findings and affirms that this was an isolated occurrence. Due to an administrative error, the affected student enrollment reflected a combination of graduate and undergraduate courses. While the withdrawal process was fully executed for the undergraduate courses, the graduate course remained active in the student information system, preventing the transaction from being recorded as a complete withdrawal. As part of the institution’s internal control and monitoring procedures, the discrepancy was detected and promptly corrected. A Return of Title IV (R2T4) calculation was performed in accordance with federal regulations. The institution remains committed to continuous improvement and regulatory compliance. Additional staff training and process reviews have been implemented to strengthen internal controls and prevent similar occurrences in the future. Corrective Action Plan To strengthen compliance and prevent recurrence, the Miami campus has implemented the Degree Audit functionality in Ellucian Colleague. This enhancement ensures that all course enrollments, term dates, and institutional charges are accurately reflected in the system, allowing the R2T4 process to operate with complete and consistent data. The R2T4 reports are already in place, and staff training, along with improved communication among Student Services and Finance offices, will reinforce timely and accurate processing. Implementation of the Degree Audit at the San Juan campus will follow the completion of a curricular change currently under development by the Academic Department. In the meantime, the San Juan campus continues to apply stricter procedures, such as requiring program director authorization before students enroll in courses outside their academic program. Anticipated completion date Immediately Name(s) of the Contact Person(s) Responsible for the Corrective Action Plan Mrs. Ileana Santiago, Controller Dr. Antonio Llorens, CIO

View Audit 383697

Finding 1170484 (2025-001)

Material Weakness 2025

Universidad Carlos Albizu, Inc.

PR

Student Financial Aid

Institutional Response The institutions agree with the auditor. This was an isolated case of the roster. The institution concurs with the auditor’s finding. We acknowledge the delay in issuing one refund beyond the required 14-day timeframe. Although this was an isolated occurrence, the University i...

Institutional Response The institutions agree with the auditor. This was an isolated case of the roster. The institution concurs with the auditor’s finding. We acknowledge the delay in issuing one refund beyond the required 14-day timeframe. Although this was an isolated occurrence, the University is committed to strengthening its internal controls and leveraging technology to prevent recurrence and ensure full compliance with federal regulations. Corrective Action Plan The institution is enhancing automation, monitoring, and accountability to ensure compliance with the 14-day refund requirement. Using Ellucian Colleague’s ODS/Informer, new reports will track Title IV credit balances and flag accounts exceeding 10 days without a refund as a preventive control. These reports will run weekly or more frequently to maintain proactive oversight. A dedicated staff member in the Student Accounts Office will be specifically assigned to process refunds within the required timeframe, ensuring clear accountability and preventing delays. The Finance organizational chart and staff assignment are under review, with the final assignment to be completed by December 1, and the reports are expected to be running by November 3. Anticipated completion date December 1, 2025 Name(s) of the Contact Person(s) Responsible for the Corrective Action Plan Mrs. Ileana Santiago, Controller Dr. Antonio Llorens, CIO

View Audit 383697

Finding 1170483 (2025-001)

Material Weakness 2025

Antelope Valley Community College District

CA

Eligibility Student Financial Aid Matching / Level of Effort / Earmarking

The financial aid office is under new leadership as of January 1, 2025. During 2025, department leadership began its review of departmental policies and procedures, focusing on remediating compliance weaknesses within the department while moving toward best practice in federal and state aid delivery...

The financial aid office is under new leadership as of January 1, 2025. During 2025, department leadership began its review of departmental policies and procedures, focusing on remediating compliance weaknesses within the department while moving toward best practice in federal and state aid delivery. Department leadership has put structures in place at multiple points of potential failure to prevent inaccurate aid calculations. These structures include new policy and procedure documentation, enhanced optimization in the Banner system, staff training in multiple modalities including intradepartmental training, asynchronous independent training, off-site training, and a monthly reconciliation program with AVC’s fiscal office. We have also begun a system of cross training to ensure that expertise persists within the department during times of staffing changes, extended leaves of absence, and vacancies.

View Audit 383685

Finding 1170384 (2025-001)

Material Weakness 2025

Treasure Valley Community College

OR

Student Financial Aid Reporting Material Weakness

Condition & Criteria: The College did not consistently report Direct Loan and Pell Grant origination/disbursement records to the COD system within the required 15-day window (or November 30, 2024 deadline), due to EDConnect software and system issues. Auditor's Recommendation: Implement additional p...

Condition & Criteria: The College did not consistently report Direct Loan and Pell Grant origination/disbursement records to the COD system within the required 15-day window (or November 30, 2024 deadline), due to EDConnect software and system issues. Auditor's Recommendation: Implement additional processes to ensure timely reporting and prompt resolution of software issues. Corrective Action: The Financial Aid department is implementing automated alerts and conducting weekly compliance checks to ensure timely and accurate processing. The team is coordinating closely with TVCC IT to prevent future delays, and software or system performance issues affecting financial aid operations will be escalated as a priority. In addition, staff will receive training on federal reporting timelines and established escalation protocols to strengthen long-term compliance. Responsible person: Director of Financial Aid, with oversight from Vice President of Student Services. Anticipated Completion Date: Begin implementation immediately and accomplish full implementation by Spring 2026; ongoing monitoring.

View Audit 383527

Finding 1170356 (2025-001)

Material Weakness 2025

Yosemite Community College District

CA

Student Financial Aid Internal Control / Segregation of Duties

Corrective action taken or planned: Management concurs with the finding and the auditor's recommendation. The District will continue to provide targeted training and perform ongoing monitoring of staff responsible for the preparation and review of R2T4 calculations. In addition, the campus will crea...

Corrective action taken or planned: Management concurs with the finding and the auditor's recommendation. The District will continue to provide targeted training and perform ongoing monitoring of staff responsible for the preparation and review of R2T4 calculations. In addition, the campus will create internal procedures for the new FAFSA simplification calculations. District will strengthen internal controls over the R2T4 process by implementing an additional level of supervisory review and approval to ensure calculations are performed accurately and in accordance with applicable federal regulations. Anticipated completion date: June 30, 2026 Contact person responsible: Melissa Raby Vice President, Student Services Columbia College

View Audit 383445

Finding 1170283 (2025-001)

Material Weakness 2025

Nova Southeastern University

FL

Internal Control / Segregation of Duties Student Financial Aid Subrecipient Monitoring

The University initiated the following remedial actions upon self-identification of the items described in the finding. 1. Updated its policies to specifically prohibit any form of compensation (including payment of bonuses and other forms of incentive compensation) or promotions for admissions depa...

The University initiated the following remedial actions upon self-identification of the items described in the finding. 1. Updated its policies to specifically prohibit any form of compensation (including payment of bonuses and other forms of incentive compensation) or promotions for admissions department personnel to be based on the achievement of enrollment goals. 2. Discontinued the prior practice of awarding office-wide bonuses for undergraduate admissions personnel. 3. Engaged higher-education industry compliance experts to consult and assist the University with the development and implementation of stronger policies and procedures in the area of personnel compensation philosophy, including job levels and standardized promotional criteria. 4. Certain management-level employees responsible for oversight of enrollment recruitment and human resources departments within the University are no longer employed by the University. 5. Enhanced competencies of its internal compliance department and strengthened the program structure and operating model, supporting improved communication and oversight.

View Audit 383410

Finding 1170229 (2025-004)

Material Weakness 2025

McMurry University

TX

Student Financial Aid Internal Control / Segregation of Duties

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: Pertinent financial aid staff will perform additional training on R2T4 regulations and implement a second review on R2T4 calculations performed. Additionally, financial aid staff will work with the staff in Online Learning Office ...

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: Pertinent financial aid staff will perform additional training on R2T4 regulations and implement a second review on R2T4 calculations performed. Additionally, financial aid staff will work with the staff in Online Learning Office of Academic Affairs to retain academic activity for all distance education students without passing grades. Person Responsible for Corrective Action Plan: Tim Sechrist, Director of Financial Aid Anticipated Date of Completion: January 31, 2026

View Audit 383253

Finding 1170214 (2025-001)

Material Weakness 2025

Victor Valley Community College District

CA

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

The delay occurred because the responsibility for processing was temporarily reassigned to another employee who had not yet received full training on the procedure. The task has been reassigned to the original staff member who has extensive experience with R2T4 processing. In addition, the Financial...

The delay occurred because the responsibility for processing was temporarily reassigned to another employee who had not yet received full training on the procedure. The task has been reassigned to the original staff member who has extensive experience with R2T4 processing. In addition, the Financial Aid Office will cross train multiple Financial Aid Specialist on the processing and tracking of R2T4 to ensure compliance and remove any delays in processing. All calculations are now being completed in compliance with federal regulations, and we have implemented measures to ensure timely processing moving forward.

View Audit 383173

Finding 1170207 (2025-001)

Material Weakness 2025

St Johns County School District

FL

Student Financial Aid Reporting Significant Deficiency

Federal Award Finding Number: 2025-001. Planned Corrective Action: Enhance procedures over the NSLDS system to ensure accurate and timely reporting moving forward. Anticipated Completion Date: June 30, 2026 Responsible Contact Person: George Mastoridis, Director of First Coast Technical College and ...

Federal Award Finding Number: 2025-001. Planned Corrective Action: Enhance procedures over the NSLDS system to ensure accurate and timely reporting moving forward. Anticipated Completion Date: June 30, 2026 Responsible Contact Person: George Mastoridis, Director of First Coast Technical College and Elizabeth Moore, Director of Accounting

View Audit 383170

Finding 1169763 (2025-001)

Material Weakness 2025

Hagerstown Community College

MD

Student Financial Aid Reporting Significant Deficiency § 200.303

U.S. Department of Education 2025-001: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During our testing of enrollment status reporting, we noted the change in enrollment status was not reported within 60 day...

U.S. Department of Education 2025-001: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During our testing of enrollment status reporting, we noted the change in enrollment status was not reported within 60 days. Recommendation: We recommend Hagerstown Community College reevaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid has contacted the National Student Clearinghouse (NSC) to assess whether any errors occurred during the file transmission process. As of the date of this submission, HCC has not received a response from NSC. Upon receipt of NSC’s findings, HCC will work collaboratively with NSC to identify the root cause of the error and implement corrective actions to prevent recurrence. HCC will continue to perform periodic spot checks of student records transmitted to NSC and subsequently reported to the National Student Loan Data System (NSLDS). Any discrepancies identified through these reviews will be addressed through coordinated corrective action by the Financial Aid, Registrar, and Institutional Effectiveness offices to ensure data accuracy and regulatory compliance. Name(s) of the contact person(s) responsible for corrective action: Dr. Charles M. Scheetz, Director of Financial Aid and W. Christopher Baer, Registrar Planned completion date for corrective action plan: June 30, 2026

View Audit 382851

Finding 1169731 (2025-001)

Material Weakness 2025

Pacific University

OR

Student Financial Aid Matching / Level of Effort / Earmarking

Name of Contact Person: Tammy Sanders, Controller, tammy.sanders@pacificu.edu Corrective Action Planned: Pacific University acknowledges the importance of an effective control environment. Management will implement proper reviews of disbursement notices to ensure timeliness and completeness. Anticip...

Name of Contact Person: Tammy Sanders, Controller, tammy.sanders@pacificu.edu Corrective Action Planned: Pacific University acknowledges the importance of an effective control environment. Management will implement proper reviews of disbursement notices to ensure timeliness and completeness. Anticipated Completion Date: January 31, 2026 Statement of Concurrence or Nonconcurrence: Pacific University management agrees with the finding.

View Audit 382800

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