Corrective Action Plans

Finding 386386 (2023-001)

Significant Deficiency 2023

NJ

Student Financial Aid Special Tests & Provisions Reporting

Management agrees with the recommendation. Corrective action by Associate VP of Enrollment Services and University Registrar is as follows: The Office of Enrollment Services has a supplemental procedure in place to capture students who graduate after the initial file submission to the National Stude...

Management agrees with the recommendation. Corrective action by Associate VP of Enrollment Services and University Registrar is as follows: The Office of Enrollment Services has a supplemental procedure in place to capture students who graduate after the initial file submission to the National Student Clearinghouse. To avoid any oversight in the future, the Office of Enrollment Services will enhance the edit report process and frequency. Effective immediately, the edit report will be generated every thirty days by the Compliance Officers to ensure all manual updates to a prior graduation are captured within the sixty-day requirement.

View Audit 298712

Finding 386305 (2023-004)

Significant Deficiency 2023

Marymount University

VA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Recommendation: We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days. We also recommend that postings to student accounts of institutional charges for each payment period be posted and dated prior to disbursing federal...

Recommendation: We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days. We also recommend that postings to student accounts of institutional charges for each payment period be posted and dated prior to disbursing federal funds to limit the number of refund checks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Student refunds will be processed weekly allowing enough time to correct any errors before the end of the 14 day period. Name(s) of the contact person(s) responsible for corrective action: Mutale Sokoni, Associate Vice President for Finance, 703-284-1496 Planned completion date for corrective action plan: March 2024

View Audit 298705

Finding 386304 (2023-003)

Significant Deficiency 2023

Marymount University

VA

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

Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in...

Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The findings were a result of data entry or date errors. Moving forward the Registrar's Office will have a second staff member review files prior to submission to ensure the accuracy of the submission to the National Student Clearinghouse. The Registrar's Office will notify Financial Aid of NSC submission dates so the FA team can verify accuracy in NSLDS. Name(s) of the contact person(s) responsible for corrective action: Dr. Meghan Arias, University Registrar, 703-284-1526 Planned completion date for corrective action plan: 3/24/24 - date of next file submission

View Audit 298705

Finding 386303 (2023-002)

Significant Deficiency 2023

Marymount University

VA

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement wi...

Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Acquired Isora GRC, a software tool to facilitate and document compliance with GLBA requirements and the corresponding NIST 800-171 information security framework. Management has also created an Enterprise Risk Management Committee which will incorporate compliance with GLBA as a top priority. Name(s) of the contact person(s) responsible for corrective action: Carl Whitman, Associate Vice President and Chief Information Officer (703-526-6901) Planned completion date for corrective action plan: Action plan by June 1, 2024, including decision regarding use of a third party or in-house resources to perform the risk assessment. Completion of 90% of action plan items within one year.

View Audit 298705

Finding 386285 (2023-001)

Significant Deficiency 2023

University of Maine System

ME

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review their reporting procedures to ensure that students’ statuses are accurately and timely reported to the National Student Loan Data System (NSLDS) within the appropriate timeframe ...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review their reporting procedures to ensure that students’ statuses are accurately and timely reported to the National Student Loan Data System (NSLDS) within the appropriate timeframe as required by regulations. University of Maine Condition: During our testing of 40 students, we noted that seven of the 17 University of Maine (UM) students tested had changes in enrollment status that were not reported in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will update its protocols for post-term reporting to the National Student Clearinghouse (NSC) each academic term to ensure students who have applied for graduation, and are pending final eligibility review, are assigned a withdrawn status until such time their degree(s) are conferred or they are reported as enrolled in a future term. Guidance received from the NSC School Operations team has been forwarded to UMS:IT, and steps to identify (or develop) and deploy the necessary reports are underway. The first round of updated reporting protocols are planned to take place in May 2024, for Spring 2024 graduation applicants. Name(s) of the contact person(s) responsible for corrective action: W. Sam Carrell, Registrar for the University of Maine Connie Smith, Director of Financial Aid for the University of Maine Planned completion date for corrective action plan: May 2024

View Audit 298686

Finding 386226 (2023-001)

Material Weakness 2023

William Paterson University of New Jersey

NJ

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Management acknowledges the finding. The finding was a result of a counselor not performing their tasks timely at a specific time period. Since the finding there is a new student financial aid director and counselor. Additionally, as this deficiency was restricted to WP online programs, the Universi...

Management acknowledges the finding. The finding was a result of a counselor not performing their tasks timely at a specific time period. Since the finding there is a new student financial aid director and counselor. Additionally, as this deficiency was restricted to WP online programs, the University has expanded staffing in that area to better coincide with an expanding population of students and to further ensure timely processing. The University identified the issue and put procedures in place to ensure that these dates will be met on an ongoing basis prior to the audit review.

View Audit 298657

Finding 386210 (2023-002)

None 2023

Lebanon Valley College

PA

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Finding 2023-002 – Enrollment Reporting Condition: The College did not notify the National Student Loan Data System (NSLDS) in a timely manner for 1 student with a status change out of a sample of 25 tested. Management Response: Management concurs with the finding. Views of Responsible Officials and...

Finding 2023-002 – Enrollment Reporting Condition: The College did not notify the National Student Loan Data System (NSLDS) in a timely manner for 1 student with a status change out of a sample of 25 tested. Management Response: Management concurs with the finding. Views of Responsible Officials and Corrective Action Plan: Lebanon Valley College uses the National Student Clearinghouse (NSC) to transmit enrollment information to the National Student Loan Data System (NSLDS). The College has verified that the student status changes were correctly submitted to the NSC, however the campus and program level information was not properly reflected in NSLDS and did not appear on the error report. This appears to be connected to the outages experienced by NSLDS. The College’s Financial Aid Office, along with the Registrar’s office will begin verifying the number of students on the NSLDS student roster each semester. The roster number will be compared to the number of students expected to be on the roster per Financial Aid data. Any discrepancies in this number will be researched and the discovery of any that did not reach NSLDS will be corrected in conjunction with the NSC and NSLDS. Anticipate Completion Date: April 1, 2024 Name of Responsible Person: Christopher Hanlon, Director of Financial Aid chanlon@lvc.edu

View Audit 298636

Finding 386186 (2023-001)

Significant Deficiency 2023

University of Detroit Mercy

MI

Student Financial Aid Reporting Significant Deficiency

Condition: The University did not accurately report the effective date of student's status change to the NSLDS. Of the 40 students selected for enrollment reporting testing, the effective date of the status change for 12 students was not accurately reported. Planned Corrective Action: The cause of t...

Condition: The University did not accurately report the effective date of student's status change to the NSLDS. Of the 40 students selected for enrollment reporting testing, the effective date of the status change for 12 students was not accurately reported. Planned Corrective Action: The cause of the error has been found to be a software issue and the University is actively working with the vendor to determine the ultimate solution. The University has implemented additional controls to ensure that the accurate effective date is reported to the NSLDS in a timely manner. Contact person responsible for corrective action: Diane M. Praet, Associate Vice President and University Registrar Anticipated Completion Date: 3/31/2024

View Audit 298616

Finding 386155 (2023-001)

None 2023

Saint Vincent College Corporation

PA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Response to Finding 2023-001: Status Changes Management Response Saint Vincent College concurs with the finding of delays in reporting changes of student enrollment status to the National Student Loan Data System (NSLDS) and attributes the delays to 1.) the first cohort of a joint program with an...

Response to Finding 2023-001: Status Changes Management Response Saint Vincent College concurs with the finding of delays in reporting changes of student enrollment status to the National Student Loan Data System (NSLDS) and attributes the delays to 1.) the first cohort of a joint program with another institution reaching completion 2.) a data breach reported by National Student Clearinghouse (NSC) in June 2023. All students identified as being reported outside of the required time period are enrolled in the joint Bachelor of Science degree in Nursing between Saint Vincent College and Carlow University that began in Fall 2019. Under the agreement for this program, the Registrar’s office of Saint Vincent College reports enrollment to the NSLDS via the NSC. Students graduate with a Carlow University degree. Saint Vincent College is to report program completers as withdrawn at the end of the final enrollment period and Carlow University is to report the students as graduated. The first cohort through this arrangement completed the program requirements in May of 2023. The students in this cohort were not included with the other student enrollment status changes reported in May 2023 following the end of the semester/graduation. While Saint Vincent did ultimately report the cohort as withdrawn, it occurred outside of the required time frame. Saint Vincent’s primary method of reporting status changes to the NSLDS is through the NSC. The NSC reported a data breach on June 26, 2023, at which point the College’s IT department instructed the Registrar to immediately stop sending data to the NSC. The resulted in the aforementioned cohort of students not being reported to the NSC or NSLDS until September 2023 when the College’s IT department provided approval for the Registrar to resume sending data to the NSC. Corrective Action Beginning March 1, 2024, Saint Vincent College’s Financial Aid Office in conjunction with Registrar’s office has implemented a 45-day report to verify that all withdrawals and completions have reached NSLDS via the National Student Clearinghouse. The discovery of any that did not reach NSLDS will be manually reported directly on the NSLDS platform to avoid being outside of the 60-day requirement. Further, during any period of known issues/outages of NSC, the College will report status changes directly to NSLDS. Conclusion The College deems that the corrective action steps outlined above will sufficiently resolve the findings and prevent any future instances of untimely reporting of enrollment data to the NSLDS. Responsible Party, Joshua A. Guiser, CPA. Vice President for Finance and Treasurer Chief Financial Officer

View Audit 298575

Finding 386133 (2023-001)

Significant Deficiency 2023

Calvin University

MI

Student Financial Aid Reporting Significant Deficiency

Finding Number: 2023-001 Condition: The University did not report the status changes of certain students to the NSLDS in an accurate and timely manner during the fiscal year. Planned Corrective Action: Campus wide operational operation software (Workday) has already implemented software updates fixi...

Finding Number: 2023-001 Condition: The University did not report the status changes of certain students to the NSLDS in an accurate and timely manner during the fiscal year. Planned Corrective Action: Campus wide operational operation software (Workday) has already implemented software updates fixing this issue. The software upgrade occurred March 24, 2023, and was operational for the 23-24 academic year. Contact person responsible for corrective action: Not applicable Anticipated Completion Date: Not applicable

View Audit 298543

Finding 386104 (2023-001)

Significant Deficiency 2023

Northwest Mississippi Community College

MS

Student Financial Aid Subrecipient Monitoring Internal Control / Segregation of Duties

Name Connie Joseph Title Controller Phone (662) 562-3292 Email cjoseph@northwestms.edu Finding 2023-001: U.S. Department of Education-Student Financial Assistance Management is in the process of developing a written information security program. Anticipated Completion Date: Prior to June ...

Name Connie Joseph Title Controller Phone (662) 562-3292 Email cjoseph@northwestms.edu Finding 2023-001: U.S. Department of Education-Student Financial Assistance Management is in the process of developing a written information security program. Anticipated Completion Date: Prior to June 30, 2024

View Audit 298492

Finding 386090 (2023-002)

Significant Deficiency 2023

Delaware College of Art and Design

DE

Questioned Costs Internal Control / Segregation of Duties Special Tests & Provisions

Internal control procedures will be strengthened between Financial Aid, the Registrar’s Office, and the Bursar’s Office.

View Audit 298459 Questioned Costs: $1

Finding 386084 (2023-001)

Significant Deficiency 2023

Miracosta Community College District

CA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

During the year-end audit testing phase, the Financial Aid office was notified in August 2023 of the deficiencies noted on this finding. The Financial Aid office immediately took action to implement the recommendations in August 2023. The District established effective controls in August 2023 to en...

During the year-end audit testing phase, the Financial Aid office was notified in August 2023 of the deficiencies noted on this finding. The Financial Aid office immediately took action to implement the recommendations in August 2023. The District established effective controls in August 2023 to ensure the return of funds occurs within 45 days from the date the institution determines the student withdrew from all classes and that the withdrawal determination is performed within the required timeframe. Additionally, the District implemented procedures in August 2023 to ensure that the academic calendar loaded in the financial aid software is accurate and based on the most up to date information. The District implemented procedures in August 2023 to ensure that the correct student status is utilized in the calculation of Return to Title IV.

View Audit 298451

Finding 386053 (2023-001)

Significant Deficiency 2023

Ripon College

WI

Special Tests & Provisions Student Financial Aid Reporting

Finding 2023-001 Sept. 26, 2023 Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the Natio...

Finding 2023-001 Sept. 26, 2023 Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that Department of Education (DOE) considers high risk. Statement of Condition: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. Corrective Action Plan: • The College agrees and concurs with the audit finding. • The Registrar’s Office has reviewed and remediated all files that were not accurately reported data elements in NSLDS as of September 2023. • The Registrar’s Office will work with the Financial Aid Office to review and regularly monitor student campus and program level enrollment status, especially in the cases of those that have dropped below full time, and are no longer enrolled for various reasons. • The Registrar’s Office will monitor the NSC error report which states discrepancies between NSC and NSLDS. • The Registrar’s Office will work with NSC to remediate processing issues between NSC and NSLDS reports in order to ensure that NSLDS is receiving accurate information. Names of Contact Persons Responsible for Corrective Action Plan: Michele Wittler (Associate Dean of Faculty and Registrar), wittlerm@ripon.edu, 920-748-8119 Katy Crane (Assistant Registrar), cranek@ripon.edu, 920-748-8119 Linda Kinziger (Director of Financial Aid), kinzigerl@ripon.edu, 920-748-8358 Anticipated Completion Date: This plan has been implemented with corrections already made as of September 2023 by the Registrar’s Office. It will be finalized with the fiscal year June 30, 2024 year-end review of Enrollment Reporting.

View Audit 298423

Finding 386017 (2023-007)

Significant Deficiency 2023

Idaho State University

ID

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

2023-007: Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Ma...

2023-007: Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: ISU should implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the intuition and are reported timely. We also recommend that the University implement a formal review procedure to document the review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During our discussion, it became apparent that a significant portion of the findings pertaining to the Office of the Registrar stemmed from enrollment status change not being reported to NSLDS within 60 days. To remedy this, we have added three new automated enrollment uploads right after the upload of the graduation file respectively in Fall, Spring and Summer. The three automated enrollment uploads to be sent to NSLDS are scheduled as follows: 1. On February 16; 2. On June 3; 3. On September 1. Name(s) of the contact person(s) responsible for corrective action: Hala Abou Arraj, Registrar Planned completion date for corrective action plan: Implemented in February 2024

View Audit 298414

Finding 385975 (2023-005)

Significant Deficiency 2023

Idaho State University

ID

Questioned Costs Special Tests & Provisions Student Financial Aid § 200.303

2023-005: Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matte...

2023-005: Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: ISU should review the requirements and implement a monitoring control to monitor the checks throughout the year. In addition, for the checks outstanding greater than 240 days, the University should return the funding to the U.S. Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ISU reopened the prior financial aid years in COD and completed returns of federal aid funds via G5/6 from identified outstanding checks. ISU has implemented the following monitoring controls: At the beginning of each month finance runs check reissue forms for all checks that the check date is 180 days or older. These are mailed to the check recipient. Around the 15th of the month any checks containing Title IV funds that have not been reissued will be turned to the financial aid office. Financial Aid is provided with the date by which the funds need to be returned. Financial Aid attempts to work with the student to get the checks cashed if they are not successful will return funds before the 240-day limit. They will then notify Finance to cancel the original check. Name(s) of the contact person(s) responsible for corrective action: Lisa Leyshon, AVP Finance/Controller, James Martin, Director of Financial Aid Planned completion date for corrective action plan: Implemented in 2020.

View Audit 298414 Questioned Costs: $1

Finding 385628 (2023-002)

Significant Deficiency 2023

Missouri Valley College

MO

Student Financial Aid Significant Deficiency

Corrective Actions: *Conduct a thorough review of the policies and procedures related to withdrawals, specifically focusing on the calculation of students' percentages of completion during the payment period and the proper handling of breaks in the academic calendar. *Implement additoinal training s...

Corrective Actions: *Conduct a thorough review of the policies and procedures related to withdrawals, specifically focusing on the calculation of students' percentages of completion during the payment period and the proper handling of breaks in the academic calendar. *Implement additoinal training sessions for staff members responsible for calculating students' completion percentages to ensure they understand the correct methodology, particularly in accounting for breaks of at least five consecutive days. *Utilize the newly implemented Ellucian Colleague software in order to monitor and identify students who withdraw and receive Title IV funds promptly. Establish a clear protocol for performing return calculations and issuing refunds within the required 45-day timeline as per federal regulations. *Enhance oversight and monitoring processes to ensure compliance with 34 CFR 668.22 and other relevant regulations. Regular audits should be conducted to verify the accuracy of calculations and the timely return of Title IV funds. *Communicate updated procedures to all relevant staff members and provide ongoing support to ensure proper implementation and adherence to the revised policies. By implementing these corrective actions, the college can address the identified deficiencies and enhance its compliance with federal regulations concerning withdrawals and the treatment of Title IV funds. All actions listed above have been completed as of 03/01/2024.

View Audit 298342

Finding 385627 (2023-001)

Significant Deficiency 2023

Missouri Valley College

MO

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

Corrective Actions: *Conduct a comprehensive review of the policies and procedures related to packaging student financial aid. Ensure that the guidelines for awarding federal direct loans align with the Federal Student Aid Handbook, Volume 3. *Utilize the newly implemented Ellucian Colleague softwa...

Corrective Actions: *Conduct a comprehensive review of the policies and procedures related to packaging student financial aid. Ensure that the guidelines for awarding federal direct loans align with the Federal Student Aid Handbook, Volume 3. *Utilize the newly implemented Ellucian Colleague software that is integrated with all offices directly involved with any facet of Title IV (registrar and billing) to follow a systematic process to review and verify student financial aid packages for accuracy. Establish protocols for identifying and rectifying instances of under-awarding federal direct subsidized loans. *Utilize Federal Student Aid training programs and other options for financial aid staff to enhance their understanding of federal regulations governing financial aid packaging. Emphasize the significance of recalculating aid packages when there are changes in FAFSA information to prevent under-awarding situations. *Create a standardized procedure for tracking and documenting FAFSA information changes and the subsequent adjustments made to financial aid packages. This will ensure transparency and accountability in the repackaging process. *Address the issue of turnover within the Financial Aid Department by implementing measures to enhance continuity and knowledge transfer. Document key processes and responsibilities to mitigate the impact of staff changes on financial aid operations. *Conduct regular internal training to ensure compliance with federal regulations and the effectiveness of the revised policies and procedures. Make adjustments as needed based on audit findings to maintain accuracy in financial aid packaging. By following these corrective actions, the College can mitigate the identified deficiencies in financial aid packaging and improve overall compliance with federal regulations. Completion Date: All actions listed above have been completed as of 03/01/2024.

View Audit 298342

Finding 385534 (2023-007)

Significant Deficiency 2023

Clarkson College

NE

Questioned Costs Student Financial Aid Significant Deficiency

2023-007 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Explanation of disagreement w...

2023-007 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clarkson College will review the R2T4 requirements and will implement procedures to ensure R2T4 calculations are completed accurately. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: July 2024

View Audit 298311 Questioned Costs: $1

Finding 385533 (2023-006)

Significant Deficiency 2023

Clarkson College

NE

Student Financial Aid Reporting Significant Deficiency

2023-006 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement wit...

2023-006 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan 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: Clarkson College will review procedures and starting immediately, all disbursements reported to COD will be reported within the appropriate timeframe. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: March 2024

View Audit 298311

Finding 385532 (2023-005)

Significant Deficiency 2023

Clarkson College

NE

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

2023-005 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding...

2023-005 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An automatic email notification will be set up in Anthology, Clarkson College’s new student information system, so that students receive a notification to their student email of their exit counseling information. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: May 2024

View Audit 298311

Finding 385531 (2023-004)

Significant Deficiency 2023

Clarkson College

NE

Internal Control / Segregation of Duties Student Financial Aid Significant Deficiency

2023-004 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained. Expl...

2023-004 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An automatic email notification has been set up in Anthology, Clarkson College’s new student information system, so that students receive a notification to their student email of their loan disbursements. Documentation is maintained in Anthology. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: March 2024

View Audit 298311

Finding 385529 (2023-002)

Significant Deficiency 2023

Clarkson College

NE

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

2023-002 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. Explanation of disagreement with audit finding: There is no disagre...

2023-002 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clarkson College will review, revise and implement procedures for cost of attendance, awarding of financial aid offers, and R2T4, in addition to the review of the process of all monthly reconciliations related to Pell, Direct Loan, SEOG and FWS along with G5 drawdowns annotated and reconciled with the Finance Department. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: July 2024

View Audit 298311

Finding 385528 (2023-001)

Significant Deficiency 2023

Clarkson College

NE

Student Financial Aid Internal Control / Segregation of Duties Reporting

2023-001 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in tit...

2023-001 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar Office reports enrollment statuses to the National Student Clearinghouse (Clearinghouse) and then the Clearinghouse reports enrollment statuses to NSLDS. Clarkson College Financial Aid will resume a procedure put in place in July 2022, according to the 2022 Corrective Action Plan, prior to the new Financial Aid staff that started in June 2023. The procedure is for one Financial Aid staff person to work with the Registrar each time enrollment is reported and that all errors are cleared in the allowed timeframe. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: April 2024

View Audit 298311

Finding 385461 (2023-005)

Significant Deficiency 2023

Community College District of Gogebic County

MI

Student Financial Aid Cash Management Significant Deficiency

Auditor Description of Condition and Effect. The College was unable to reconcile direct loans with the COD website during fiscal 2023. The College was unable to obtain the COD reports needed for monthly direct loan reconciliations. As a result of this condition, the College isn't meeting its obliga...

Auditor Description of Condition and Effect. The College was unable to reconcile direct loans with the COD website during fiscal 2023. The College was unable to obtain the COD reports needed for monthly direct loan reconciliations. As a result of this condition, the College isn't meeting its obligation to complete reconciliations of direct loans on a monthly basis and risks overdrawing. Auditor Recommendation. We recommend that the College communicate with other schools to develop a policy for handling matters such as these when having technology issues. Corrective Action. Currently, the College has fixed this error and is now able to pull the correct reports from the COD website. The College intends to perform reconciliations of direct loans on a monthly basis going forward. Responsible Person. Maryann Decaire, Director of Financial Aid. Anticipated Completion Date. June 30, 2024.

View Audit 298275

Corrective Action Plans

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