Corrective Action Plans

Finding 384707 (2023-002)

Significant Deficiency 2023

MA

Questioned Costs Student Financial Aid

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Federal Pell Grants AL #’s: 84.063 Award year: 2023 Corrective Action Plan: Once the new Federal Pell Grant amounts are announced by the DOE, the Director will run a report of all students that have already been awarded ...

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Federal Pell Grants AL #’s: 84.063 Award year: 2023 Corrective Action Plan: Once the new Federal Pell Grant amounts are announced by the DOE, the Director will run a report of all students that have already been awarded a Federal Pell Grant to recalculate their Federal Pell Grant amount. Additionally, an internal audit will be done after the first disbursements are done in the Fall to ensure that all students are receiving the correct Pell amount. Timeline for Implementation of Corrective Action Plan: This policy was already implemented and began with the 2023-2024 academic year. Contact Person Catherine Kedski, Director of Student Financial Services

View Audit 297824 Questioned Costs: $1

Finding 384706 (2023-001)

Significant Deficiency 2023

Massachusetts Maritime Academy

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans AL #’s: 84.268 Award year: 2023 Corrective Action Plan: The Loan Counselor will automatically submit a Direct Loan disbursement report immediately following the disbursement of any federal lo...

Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans AL #’s: 84.268 Award year: 2023 Corrective Action Plan: The Loan Counselor will automatically submit a Direct Loan disbursement report immediately following the disbursement of any federal loan. The Director will monitor when the Loan Counselor runs any disbursements and confirm that the disbursement report has been sent to COD in a timely fashion. Timeline for Implementation of Corrective Action Plan: This plan has already been implemented beginning with the 2023-2024 academic year. Contact Person Catherine Kedski, Director of Student Financial Services

View Audit 297824

Finding 384694 (2023-007)

Significant Deficiency 2023

Columbia College

MO

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

2023-007 Exit Counseling (Significant Deficiency) Criteria: Federal regulations stipulate that an institution must ensure that exit counseling is conducted with each Federal Direct Loan borrower shortly before the student borrower ceases at least half-time study at the school. If a student borrower ...

2023-007 Exit Counseling (Significant Deficiency) Criteria: Federal regulations stipulate that an institution must ensure that exit counseling is conducted with each Federal Direct Loan borrower shortly before the student borrower ceases at least half-time study at the school. If a student borrower withdraws from the school without prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower’s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Condition: During our testing, we noted eight instances, in a sample of nine students requiring exit counseling, in which evidence of exit counseling and notification of exit counseling could not be provided by the College. Action Taken: We concur with this finding. Currently, students receive a withdrawal notification that provides them with a link to complete their exit counseling. Moving forward and during the completion of the withdrawal, the students will be presented with an exit counseling digital page. On this page, withdrawal information will be provided to the student along with the deadline to complete the exit counseling. Students will also certify that they have received and understood the information. Once the withdrawal form is completed, students will get a follow up email that will also direct them to the exit counseling at www.studentaid.gov and inform them of the 30-day deadline. Responsible Party: Lola Kennedy, Senior Director of Financial Aid and Sharon Murphy, Registrar Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) and Sharon Murphy, Registrar (smurphy@columbiasc.edu) Expected date of correction: April 1, 2024

View Audit 297799

Finding 384693 (2023-006)

Significant Deficiency 2023

Columbia College

MO

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

2023-006 Return of Title IV Funds (Significant Deficiency) Criteria: When a recipient of Title IV grant or loan assistance withdraws from a school during a payment period in which the recipient began attendance, the school must determine the amount of Title IV assistance earned by the student as of ...

2023-006 Return of Title IV Funds (Significant Deficiency) Criteria: When a recipient of Title IV grant or loan assistance withdraws from a school during a payment period in which the recipient began attendance, the school must determine the amount of Title IV assistance earned by the student as of the student’s withdrawal date. If the total of the Title IV assistance earned by the student is less than the amount that was distributed to the student, the difference must be returned to the Title IV programs. A school must return Title IV funds to the programs from which the student received aid as soon as possible but no later than 45 days after the date of determination of a student’s withdrawal. Condition: From a population of 61 students that withdrew during the fiscal year, we tested seven and noted that six of the seven required a refund calculation and return of funds. Four of the students refund calculations were not completed in a timely fashion and two students that completed a withdrawal form did not have a refund calculations prepared. The College did not return Title IV funds for the two students that should have had refund calculations and the College did not return Title IV funds within 45 days after the date of determination of the student’s withdrawal for the four students that had refund calculations prepared. Action Taken: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the communication list for withdrawals was updated with the Director of Financial Aid’s information to ensure the financial aid office receives all withdrawal information in a timely manner. Responsible Party: Lola Kennedy, Senior Director of Financial Aid Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) Expected date of correction: July 2023

View Audit 297799

Finding 384692 (2023-005)

Significant Deficiency 2023

Columbia College

MO

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

2023-005 Reporting Student Withdraw Date in the National Student Loan Data System (NSLDS) (Significant Deficiency) Criteria: The College is responsible for submitting timely, accurate and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordance ...

2023-005 Reporting Student Withdraw Date in the National Student Loan Data System (NSLDS) (Significant Deficiency) Criteria: The College is responsible for submitting timely, accurate and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordance with 34 CFR Section 685.309(a)(2). Condition: From a population of 61 students that withdrew during the fiscal year, we tested seven and noted that six of the seven required a refund calculation and return of funds. The change in status was not reported to NSLDS for one student and the last date of the semester was reported instead of the withdrawal date for four students. Action Taken: The Registrar’s Office maintains the institution’s enrollment records. During the fall of 2023, the enrollment reporting process was moved to the Registrar’s Office to ensure the accuracy of reporting. Responsible Party: Sharon Murphy, Registrar Point of Contact: Sharon Murphy, Registrar (smurphy@columbiasc.edu) Expected date of correction: August 2023

View Audit 297799

Finding 384691 (2023-004)

Significant Deficiency 2023

Columbia College

MO

Student Financial Aid Significant Deficiency

2023-004 Incorrect Calculation of Title IV Funds Refunds (Significant Deficiency) Criteria: The total number of calendar days in a payment period or period of enrollment includes all days within the period that a student was scheduled to complete, except that scheduled breaks of at least five consec...

2023-004 Incorrect Calculation of Title IV Funds Refunds (Significant Deficiency) Criteria: The total number of calendar days in a payment period or period of enrollment includes all days within the period that a student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. If a student withdrawals by providing notification to designated officials, the withdrawal date is the date notification was provided. Institutional charges used in the refund calculation are the charges that were initially assessed the student for the entire payment period. Condition: From a population of 61 students that withdrew during the fiscal year, we tested seven and noted that four of the seven had refund calculations prepared. From these calculations we noted the following: 1. Breaks of five or more consecutive days were not deducted from total days in all refunds. 2. The date of the college’s determination was used as the withdrawal date for three of the four students.3. Institutional charges for the period used in the refund calculations included tuition and fee credits processed due to the withdrawal for two of the four students. Action Taken: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the staff attend internal and external training on R2T4 processing along with other regulations. System updates are performed during the Fall semester for the next year. During this update, R2T4 parameters are set and monitored to ensure accuracy. In addition, the R2T4 calculations now include adjustments made to the students’ account at the time of withdrawal. Responsible Party: Lola Kennedy, Senior Director of Financial Aid Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) Expected date of correction: August 1, 2023

View Audit 297799

Finding 384690 (2023-003)

Significant Deficiency 2023

Columbia College

MO

Student Financial Aid Significant Deficiency

2023-003 Treatment of a student who fails to receive a passing grade in any class (Significant Deficiency) Criteria: An institution must have a procedure for determining whether a Title IV aid recipient who began attendance during a period completed the period or should be treated as a withdrawal. I...

2023-003 Treatment of a student who fails to receive a passing grade in any class (Significant Deficiency) Criteria: An institution must have a procedure for determining whether a Title IV aid recipient who began attendance during a period completed the period or should be treated as a withdrawal. If a student who began attendance and has not officially withdrawn fails to earn a passing grade in at least one course offered over an entire period, the school must assume, for Title IV purposes, that the student has unofficially withdrawn, unless the institution can document that the student completed the period. In the absence of evidence of a last day of attendance, a school must consider a student who failed to earn a passing grade in all classes to be an unofficial withdrawal. Condition: From a population of 140 students that received all failing grades in a term, we tested fourteen students and noted that documentation of the last date of attendance could not be provided for any of the students tested. Action Taken: We concur with this finding. With enhancements to the Jenzabar ONE system, the institution has implemented a new process that requires professors to enter the Last Day of attendance (LDA) for any student who earned an F grade. Going forward, the Registrar will present a report to the Office of Financial Aid two days after final grades post for the semester. The report will have the students who have all Fs with their LDS listed for each class. Responsible Party: Lola Kennedy, Senior Director of Financial Aid Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) Expected date of correction: April 2024

View Audit 297799

Finding 384689 (2023-002)

Significant Deficiency 2023

Columbia College

MO

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

2023-002 Disbursement of Title IV Funds (Significant Deficiency) Criteria: An institution must disburse during the current payment period, with certain qualifying exceptions, the amount of Title IV, HEA program funds that a student enrolled at the institution, or the student’s parent, is eligible to...

2023-002 Disbursement of Title IV Funds (Significant Deficiency) Criteria: An institution must disburse during the current payment period, with certain qualifying exceptions, the amount of Title IV, HEA program funds that a student enrolled at the institution, or the student’s parent, is eligible to receive for that payment period, 34 CFR 668.164(b)(1). Condition: During our testing, we noted three instances in a sample of 26 students in which Direct Loan awards were not disbursed to the student during the payment period. Qualified exceptions were not met and the three students received disbursements for the 2022-2023 academic year on August 14, 2023. Action Taken: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the staff attend internal and external training sessions regularly. Currently, disbursements are processed at least 3 times a week. The Office of Financial Aid works diligently to ensure all funds are fully disbursed by the end of each semester. Responsible Party: Lola Kennedy, Senior Director of Financial Aid Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) Expected date of correction: January 2024

View Audit 297799

Finding 384688 (2023-001)

Material Weakness 2023

Columbia College

MO

Student Financial Aid Material Weakness Reporting

2023-001 Special Reporting – Fiscal Operations Report and Application to Participate (FISAP) (Material Weakness) Criteria: As a Campus-Based Program participant, the College is required to submit an accurate FISAP yearly by October 1. The information reported on the FISAP is used to determine the s...

2023-001 Special Reporting – Fiscal Operations Report and Application to Participate (FISAP) (Material Weakness) Criteria: As a Campus-Based Program participant, the College is required to submit an accurate FISAP yearly by October 1. The information reported on the FISAP is used to determine the school’s Campus Based Program funding for the upcoming award year as well as report Campus‑Based Program expenditures for the prior award year. The College is required to submit a Fiscal Operations Report plus other information required; the information must be accurate and shall be submitted on the form at the time specified, 34 CFR 674.19(d)(2). Condition: During our review of the College’s FISAP it was determined that tuition and fee revenue was overstated and Pell amount reported was understated. Action Taken: We concur with this finding. Staff made a “change request” to the US Department of Education (USDOE) to adjust the FISAP. Once the “change request” was approved by the USDOE, we edited the FISAP report to appropriately reflect the audited numbers. It is important to note that the FISAP is due by September 30th, and the USDOE allows institutions until December 15th to adjust the figures. Our audited financial statements are due no later than September 30th, which normally allows time to ensure that the figures on the FISAP are reconciled to the ones on the audited financial statements. Nevertheless, if the audited statements are not completed by the September 30th deadline, we will make sure that any adjusting entries to the FISAP are made by the final date of December 15th. Responsible Party: Lola Kennedy, Senior Director of Financial Aid Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) Expected date of correction: February 2024

View Audit 297799

Finding 384673 (2023-001)

Significant Deficiency 2023

Bristol Community College

MA

Student Financial Aid Matching / Level of Effort / Earmarking

Corrective Action Plan To ensure that there are no further instances of late return of title IV funds due to withdrawals, the financial aid office has updated their process. As a quality assurance measure, every withdrawal processed by the Registrar’s office will be sent to three individuals in the ...

Corrective Action Plan To ensure that there are no further instances of late return of title IV funds due to withdrawals, the financial aid office has updated their process. As a quality assurance measure, every withdrawal processed by the Registrar’s office will be sent to three individuals in the FA office- Director, Associate Director, and Withdrawal Coordinator. After the final withdrawal report from the Registrar’s office has been processed each semester, all students will be reviewed individually by Director, Associate Director, and Coordinator. The manual review process will ensure that all reported students have been appropriately reviewed and processed within the required timeframe. This updated process will eliminate the human error associated with the finding. Timeline for Implementation of Corrective Action Plan Implemented Fall 2023 Contact Person: Alaina Marcotte, Director Financial Aid

View Audit 297771

Finding 384582 (2023-003)

Material Weakness 2023

Metro Technology Center

OK

Student Financial Aid Reporting Material Weakness

Finding Summary: Various discrepancies were noted in the National Student Loan Data System. Responsible Individuals: Alicia Smith, Director of Financial Aid Corrective Action Plan: We have worked to implement a process to quickly update student enrollment status in all financial aid systems to ensur...

Finding Summary: Various discrepancies were noted in the National Student Loan Data System. Responsible Individuals: Alicia Smith, Director of Financial Aid Corrective Action Plan: We have worked to implement a process to quickly update student enrollment status in all financial aid systems to ensure proper reporting. Anticipated Completion Date: July 1, 2024

View Audit 297658

Finding 384579 (2023-002)

Significant Deficiency 2023

Metro Technology Center

OK

Student Financial Aid Reporting Significant Deficiency

Finding Summary: One financial aid disbursement tested was not made within the allowable 15 day period. Responsible Individuals: Alicia Smith, Director of Financial Aid Cari Wilburn, Director of Finance Corrective Action Plan: We have worked together in both departments to ensure proper reporting on...

Finding Summary: One financial aid disbursement tested was not made within the allowable 15 day period. Responsible Individuals: Alicia Smith, Director of Financial Aid Cari Wilburn, Director of Finance Corrective Action Plan: We have worked together in both departments to ensure proper reporting on the financial aid systems and quick disbursements of all funds. Anticipated Completion Date: July 1, 2024

View Audit 297658

Finding 384532 (2023-001)

Significant Deficiency 2023

Fairfield University

CT

Student Financial Aid Special Tests & Provisions Reporting

Finding No. 2023-001 – Significant Deficiency and Noncompliance: Special Tests and Provisions – Enrollment Reporting Corrective Action The corrective action that will be taken is a graduates only enrollment report will be supplied to the National Student Clearinghouse (NSC) by the Registrar’s Offi...

Finding No. 2023-001 – Significant Deficiency and Noncompliance: Special Tests and Provisions – Enrollment Reporting Corrective Action The corrective action that will be taken is a graduates only enrollment report will be supplied to the National Student Clearinghouse (NSC) by the Registrar’s Office on a consistent schedule of submission within 60 days of each graduation period. Persons Responsible for Corrective Action The corrective action plan will be completed by Walter Rankin, Vice Provost for Graduate Continuing and Professional Studies and Danielle Quilligan, University Registrar. Completion Date Initial corrective action was completed by Lynn Kohrn, University Registrar and Allison Henderson, Assistant Registrar in October, 2023 with the submission of a graduates only enrollment report to the third-party service provider NSC. A schedule for consistent submissions of a graduates only enrollment report has already been provided to the NSC.

View Audit 297643

Finding 384358 (2023-001)

Material Weakness 2023

Eastern University

PA

Student Financial Aid Material Weakness Reporting

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Determining the last date of academically related activity for Return of Title IV Funds was identified as a finding from last audit year (2021-2022). A Department of Education review was completed and once this was done and deter...

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Determining the last date of academically related activity for Return of Title IV Funds was identified as a finding from last audit year (2021-2022). A Department of Education review was completed and once this was done and determined that we made the proper adjustments for 21-22, a complete and detailed review for 22-23 to correct any incorrect R2T4’s was completed. This resulted in untimely returns but has since been resolved. Person Responsible for Corrective Action Plan: Andrea Ruth, Director of Financial Aid Anticipated Date of Completion: August 2023

View Audit 297474

Finding 384354 (2023-001)

Significant Deficiency 2023

University of Denver

CO

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated fed...

Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: As of January 2024, the University implemented a monthly process for the coordinated review of stale-dated checks. After the close of each month, the Accountant II and Business Analyst in the Controller’s Office prepares a report of stale-dated checks and sends the report to the Assistant Director of Student Accounts and the Student Accounts Business Analyst in University Financial Services. These staff members identify federal funds to be returned to the Department of Education. The Office of Student Accounts works with the Office of Financial Aid to ensure funds are returned. This process has addressed any backlog of checks, and the monthly process keeps the University current in processing stale-dated checks and returning funds in a timely manner. Name of the contact person responsible for corrective action: Andrew Cullen, Associate Vice Chancellor, Finance and Janet Burkhardt, Assistant Vice Chancellor, University Financial Services. Planned completion date for corrective action plan: Effective immediately.

View Audit 297469 Questioned Costs: $1

Finding 384353 (2023-002)

Significant Deficiency 2023

University of Denver

CO

Student Financial Aid Matching / Level of Effort / Earmarking

Condition: During our testing, we noted two of the Perkins files in which the MPN was not retained on file for loans with outstanding balances. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: The University determined th...

Condition: During our testing, we noted two of the Perkins files in which the MPN was not retained on file for loans with outstanding balances. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: The University determined there are a total of 39 Perkins loans with missing MPNs. Of these, 6 loans are with 3rd party collection agencies, 19 are paid in full and 14 are in repayment. For these 39 loans, the University determined that alternative documentation such as exit counseling and repayment records has been retained. The Perkins Assignment and Liquidation Guide (p.4), ED tells schools to collect alternative documentation, explain the reason the note is missing and affirm the school has searched all records for each loan missing documentation. Due to the discontinuance of the Perkins loan program, no new MPNs will be issued. Name of the contact person responsible for corrective action: Andrew Cullen, Associate Vice Chancellor, Finance and Janet Burkhardt, Assistant Vice Chancellor, University Financial Services. Planned completion date for corrective action plan: Corrective action plan completed in August 2023.

View Audit 297469

Finding 384322 (2023-003)

Significant Deficiency 2023

Erikson Institute

IL

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

Finding 2023-003: Cash Management The Institute had three instances of return of funds that resulted in excess cash for Federal Direct Student Loans ranging from $94 to $46,049 during the period of September 19, 2022 through November 29, 2022. In these situations, the excess cash, being less than ...

Finding 2023-003: Cash Management The Institute had three instances of return of funds that resulted in excess cash for Federal Direct Student Loans ranging from $94 to $46,049 during the period of September 19, 2022 through November 29, 2022. In these situations, the excess cash, being less than one percent of total prior year drawdowns, were not returned within a seven day tolerance period. Corrective Action Plan A Student Bursar was hired in November 2022 and onboarding included comprehensive federal funds cash management training with an outside consultant. A review of cash management policies in place was conducted at that time and monitoring procedures and reconciliations were enhanced to eliminate excess cash. Contact Person Christine Frankhauser Controller cfrankhauser@erikson.edu Anticipated Completion Date January 2023

View Audit 297439

Finding 384321 (2023-002)

Significant Deficiency 2023

Erikson Institute

IL

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

Finding 2023-002: Enrollment Reporting For two out of four students tested (50%) who withdrew from the Institute, the students’ enrollment status reported to the National Student Loan Data System (NSLDS) did not match the institution’s records. Corrective Action Plan The Director of Research, Reg...

Finding 2023-002: Enrollment Reporting For two out of four students tested (50%) who withdrew from the Institute, the students’ enrollment status reported to the National Student Loan Data System (NSLDS) did not match the institution’s records. Corrective Action Plan The Director of Research, Registration, & Records, who oversees the Registration & Records office has taken steps to ensure timely and accurate reporting moving forward. In summer 2023, a new full-time Registrar was hired to oversee the office. Additionally, Erikson has updated the functioning of its student information system in ways that are compatible with timely and accurate reporting. Changes to the system have been tested and implemented. Lastly, Erikson created a new Business Analyst position and is in the process of hiring to oversee administration and maintenance of the student information system in ways that will continue to facilitate timely reporting and data integrity. Contact Person Leanne Beaudoin Ryan, PhD Director of Research, Registration, & Records lbeaudoinryan@erikson.edu Anticipated Completion Date Updates to processes and procedures were completed in September 2023. Transition from outsourced staffing to the newly-created position is expected by May 2024.

View Audit 297439

Finding 384307 (2023-002)

Significant Deficiency 2023

Desert Community College District

CA

Student Financial Aid Reporting Significant Deficiency

The District concurs with the finding. The District will establish new procedures to verify student Enrollment Reporting Roster data before submission. This will allow the district to identify discrepancies and make necessary adjustments and to ensure accurate information is reflected in the NSLDS w...

The District concurs with the finding. The District will establish new procedures to verify student Enrollment Reporting Roster data before submission. This will allow the district to identify discrepancies and make necessary adjustments and to ensure accurate information is reflected in the NSLDS website.

View Audit 297438

Finding 384306 (2023-001)

Significant Deficiency 2023

Desert Community College District

CA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

The District concurs with the finding. The District will establish procedures such as monthly reconciliation for return to Title IV calculations to identify the funds that need to be returned and ensure that funds are returned within 45 days.

View Audit 297438

Finding 384289 (2023-002)

None 2023

Trinity Bible College and Graduate School

ND

Student Financial Aid Reporting Internal Control / Segregation of Duties

2023-002 FISAP Reporting Planned Corrective Action: Trinity Bible College and Graduate School has implemented policies and procedures to address the gaps in reporting Perkins information related to the FISAP report. A new director of Financial Aid has been put in place to help ensure proper reporti...

2023-002 FISAP Reporting Planned Corrective Action: Trinity Bible College and Graduate School has implemented policies and procedures to address the gaps in reporting Perkins information related to the FISAP report. A new director of Financial Aid has been put in place to help ensure proper reporting. Person Responsible for Corrective Action Plan: Executive Vice President Vaughn Jordan, Director of Financial Aid Wesley Brothers, and Coordinator of Financial Aid Shannon Pool. Anticipated Date of Completion: CAP has already been implemented regarding this issue.

View Audit 297426

Finding 384249 (2023-005)

Significant Deficiency 2023

Manhattan School of Music

NY

Student Financial Aid

The school will continue to effectively streamline processes regarding leaves of absences and withdrawals and data entry into the Student Information System (SIS). In part, the separation dates will be manually entered with the National Student Clearinghouse (NSC). To note, the school permits studen...

The school will continue to effectively streamline processes regarding leaves of absences and withdrawals and data entry into the Student Information System (SIS). In part, the separation dates will be manually entered with the National Student Clearinghouse (NSC). To note, the school permits students to take leave of absences (LOA) for up to two semesters, which is greater than the Federal Student Aid (FSA) allows (180 days). The Registrar’s Office codes students on leave with a separation date in our SIS, the student will also be coded as such with NSC. If the student does not return from a LOA after 180 days (6 months), the NSC student record will be updated to a withdrawn status effective one day before or one day after the leave began as recommended by NSC.

View Audit 297400

Finding 384248 (2023-004)

Material Weakness 2023

Manhattan School of Music

NY

Student Financial Aid

The School’s Finance and Financial Aid departments will more closely coordinate the vetting of the numbers before entering on FISAP. The two departments will schedule annual meeting to discuss and review the numbers.

View Audit 297400

Finding 384247 (2023-003)

Significant Deficiency 2023

Manhattan School of Music

NY

Student Financial Aid Matching / Level of Effort / Earmarking

Monthly reconciliation reports resumed in a more detailed manner effective December 2022 with the arrival of the new Senior Associate Director of Financial Aid. The process was a collaborative effort between the Senior Associate Director and MSM’s Financial Aid consultant through August 2023 after w...

Monthly reconciliation reports resumed in a more detailed manner effective December 2022 with the arrival of the new Senior Associate Director of Financial Aid. The process was a collaborative effort between the Senior Associate Director and MSM’s Financial Aid consultant through August 2023 after which the function resides with the Senior Associate Director.

View Audit 297400

Finding 384226 (2023-003)

None 2023

Hannibal-Lagrange University

MO

Reporting Student Financial Aid Eligibility

Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A representative from the Registrar’s Office will meet monthly with a representative of the Financial Aid Office to provide spot-checks and quality assurance to the student information uploaded to NSLDS. St...

Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A representative from the Registrar’s Office will meet monthly with a representative of the Financial Aid Office to provide spot-checks and quality assurance to the student information uploaded to NSLDS. Student information is uploaded to the NSLDS monthly, so this should provide another layer of assurance each time information is submitted. An internal deadline and standing meeting will be established to ensure consistent compliance. Person Responsible for Corrective Action Plan: Joseph D. Garner III, Registrar Anticipated Date of Completion: The new process will begin April, 2024.

View Audit 297334

Corrective Action Plans

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