Corrective Action Plans

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FINDING 2025-008 Name of Responsible Individual: Tracey Jenkins, Student Account Billing Coordinator/Lisa Simon, CPA, CFO Corrective Action: Wheeling University worked with ECSI regarding Perkins information last year. With the Perkins program ending, we realized that we needed to move in the direct...
FINDING 2025-008 Name of Responsible Individual: Tracey Jenkins, Student Account Billing Coordinator/Lisa Simon, CPA, CFO Corrective Action: Wheeling University worked with ECSI regarding Perkins information last year. With the Perkins program ending, we realized that we needed to move in the direction of closing out Perkins files/information. The University is currently working with ECSI so that we can submit Perkins information/files to the Department of Education. We have gathered information (promissory notes, bankruptcy details, payment information, etc.) as we have been able to locate it, and and we have sorted account in alpha order to assist ECSI with the process. We will continue to update this process. Anticipated Completion Date: June 2026
FINDING 2025-007 Name of Responsible Individual: Lisa Simon, CFO, Terri Helt, Senior Accountant, & Dylan J. Nowakowski, Director of Financial Aid Corrective Action: Wheeling University acknowledges that we were not in compliance with the 15-day reporting window for a couple of the students in questi...
FINDING 2025-007 Name of Responsible Individual: Lisa Simon, CFO, Terri Helt, Senior Accountant, & Dylan J. Nowakowski, Director of Financial Aid Corrective Action: Wheeling University acknowledges that we were not in compliance with the 15-day reporting window for a couple of the students in question. This is due to the fact that the University is on HCM1 and has to do refunds prior to the export to COD. We know this is a finding for multiple departments and internal controls. With that, there was a delay on these two students that were outside the 15-day window. We now have a policy and procedure in place for the HCM1 work flow. Also, have new staff in place to regulate this, so that we always are following the regulations and staying compliant. The procedure is to make sure we do not have this finding again and that we stay in compliance with the Department of Education reporting requirement. Anticipated Completion Date: September 2025 and Ongoing
FINDING 2025-006 Name of Responsible Individual: Rachel Heavilin, HR Generalist/Payroll Corrective Action: The payroll Process for Federal Work Study: Student punches in on a computer or cell phone to log in and out when working at the start of their shift and the end of their shift. Timecards can b...
FINDING 2025-006 Name of Responsible Individual: Rachel Heavilin, HR Generalist/Payroll Corrective Action: The payroll Process for Federal Work Study: Student punches in on a computer or cell phone to log in and out when working at the start of their shift and the end of their shift. Timecards can be approved by their supervisor/manager daily, weekly, or by the pay period which is every two weeks. The pay period ends on a Friday with the payroll processing to begin on the following Monday. On that Monday, all timecards must be corrected/updated and approved before they can be processed. Timecards with errors cannot be processed. Once the new HR and Payroll leader arrived, she instituted this approval process and requirement and checks and balances. Staff are trained in these processes upon hiring as well. Anticipated Completion Date: November 2025
FINDING 2025-005 Name of Responsible Individual: Dylan J. Nowakowski, Director of Financial Aid Corrective Action: After Colleague was properly set up for Financial Aid for R2T4’s, the Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been...
FINDING 2025-005 Name of Responsible Individual: Dylan J. Nowakowski, Director of Financial Aid Corrective Action: After Colleague was properly set up for Financial Aid for R2T4’s, the Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of five days or more, then the R2T4 would have been accurate. The R2T4 process has been working correctly following our R2T4 policy to make sure the days are correct in the system before the R2T4 is submitted. For the years moving forward this will be verified before any R2T4 is calculated and submitted. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break. Anticipated Completion Date: July 2025
FINDING 2025-004 Name of Responsible Individual: Tracy Jenkins, Student Account Billing Coordinator Corrective Action: We recognized that students were not receiving the Right to Cancel notifications in a timely manner. We also understood the need for students to receive this information to make an ...
FINDING 2025-004 Name of Responsible Individual: Tracy Jenkins, Student Account Billing Coordinator Corrective Action: We recognized that students were not receiving the Right to Cancel notifications in a timely manner. We also understood the need for students to receive this information to make an important educational/fiscal decision. As of September 2023, on a monthly basis, notifications were sent to student University emails and parent’s personal email (Plus Loan recipients) informing them of their Right to Cancel. There was one student that was at 31 days and this process has been updated. Anticipated Completion Date: January 2025
FINDING 2025-003 Name of Responsible Individual: Shelia Yates-Mattingly, Registrar Corrective Action: In response to Finding 2025-003, Wheeling University will continue the enrollment reporting process that was implemented in October 2023, which was in response to Finding 2022-005, Finding 2023-005 ...
FINDING 2025-003 Name of Responsible Individual: Shelia Yates-Mattingly, Registrar Corrective Action: In response to Finding 2025-003, Wheeling University will continue the enrollment reporting process that was implemented in October 2023, which was in response to Finding 2022-005, Finding 2023-005 and continued with the Finding 2024-003. With the stability of staffing in the Registrar’s Office and Financial Aid Office and the level of experience and competence of this staff, enrollment reporting has been completed within the parameters of regulatory guidelines. The Registrar’s Office submits enrollment reports as scheduled and subsequent error resolution reports as appropriate. The Financial Aid Office reviews identified NSLDS errors, corrects and resubmits them timely. Regularly scheduled meetings, including the Registrar’s and Financial Aid Offices, continue as noted in corrective actions for Findings 2022-005, 2023-005, and 2024-003. These meetings serve as the platform to discuss and address identified enrollment reporting concerns/issues timely, resulting in improved accuracy in enrollment reporting and timeliness in error resolution. In addition, attendance through Census will be monitored in an effort better identify registered but not enrolled students for administrative action and timely reporting. Institutional enrollment reports will be used to identify students who have chosen not to continue their studies at the University but without withdrawing from the institution to alert departments to execute their operational protocols for students who have discontinued enrollment. Students who officially withdraw pursuant to established University protocols will be required to consult with Financial Aid during this process. University departments will continue to be informed of student withdrawals as they occur to inform their practices. Anticipated Completion Date: Processes in place since October 2023; new measures implemented January 2025
FINDING 2025-002 Name of Responsible Individual: Terri Helt, Senior Accountant Corrective Action: The University has formalized and documented financial processes to establish internal controls to ensure accurate, timely, and consistent reporting. In addition, this has created a reasonable transitio...
FINDING 2025-002 Name of Responsible Individual: Terri Helt, Senior Accountant Corrective Action: The University has formalized and documented financial processes to establish internal controls to ensure accurate, timely, and consistent reporting. In addition, this has created a reasonable transition plan during employee turnover, as well as ensures proper and timely filings. The corrective action involves drawing down the funds from the G5 federal website and issuing refunds to students that day. There is a checks and balance process built in, so multiple staff members are involved with the process. The financial aid department calculates the amount of a federal drawdown and relays that information to the business department. The senior accountant draws the appropriate amount of federal financial aid. The student accounts billing coordinator applies aid to the various student accounts in the software. After the aid has been applied, the student accounts billing coordinator determines if a refund is due to the students. Any student that is entitled to a refund will be cut for a refund check that day. The students will then have a window of opportunity to come pick up the refund checks. Within two business days, any students who have not picked up their refund checks will have them mailed to their address on file with the University. This process has been developed to ensure that students receive their refunds in a timely and accurate manner. Anticipated Completion Date: Completed July 2025 and Ongoing
The University will more closely review the data submitted regarding tuition and fees being reported on the FISAP. This will include validating and reconciling the amounts reported on the FISAP to the University's general ledger. This has been completed as of March 2, 2026 for fiscal year 2024-2025.
The University will more closely review the data submitted regarding tuition and fees being reported on the FISAP. This will include validating and reconciling the amounts reported on the FISAP to the University's general ledger. This has been completed as of March 2, 2026 for fiscal year 2024-2025.
The Financial Aid staff will receive ongoing training on accurate determination of withdrawal date, last date of attendance (LDA), and correct payment period start and end dates. The Director and Assistant Director will review all R2T4 calculations for accuracy prior to finalization, including verif...
The Financial Aid staff will receive ongoing training on accurate determination of withdrawal date, last date of attendance (LDA), and correct payment period start and end dates. The Director and Assistant Director will review all R2T4 calculations for accuracy prior to finalization, including verification of withdrawal date, LDA, and payment period start and end dates. The Director and Assistant Director will ensure that all applicable funds are returned to the Department of Education and properly removed from the students' accounts within the required time frame.
The East Central University Records Office reports enrollment to the National Student Clearinghouse (NSC). The NSC then transmits that data to the National Student Loan Data System (NSLDS) where it becomes part of the financial aid record. The graduate student enrollment status issue was addressed i...
The East Central University Records Office reports enrollment to the National Student Clearinghouse (NSC). The NSC then transmits that data to the National Student Loan Data System (NSLDS) where it becomes part of the financial aid record. The graduate student enrollment status issue was addressed in March 2025 as a result of the 2024-year audit. Importantly, because that correction was made in March of 2025, it was expected that the 2025-year audit identified Spring 2025 semester students prior to when the correction was made. The Records Office is confident this particular issue was fully resolved in March 2025 in accordance with the action plan put forward at the time. With regard to the student's status effective date differing between NSLDS and Colleague, considerable time has been devoted to investigating this case. This includes a one-hour consultation with Strata information Group (SIG) on 3/6/2026. However, ECU is not able to determine where the date reported to NSLDS came from. Much review of the Colleague to NSC reporting procedures has taken place since Fall 2024, which gives the Records Office confidence that whatever the cause of this data discrepancy, it is unlikely to represent a current systemic problem. However, the Records Office will add to the list of preliminary data checks (i.e. , prior to submitting the Colleague file to NSC), to randomly select students who have a within-term change of status and verify that the date in the NSC file matches what we expect to see in Colleague. With regard to Spring graduated status effective dates exceeding the end of the term, while working with the SIG consultant to review procedures for NSC reporting, it was noticed that Colleague requires NSC reporting period dates to not exceed the end of term. This caused the Records Office to raise the question of the award date. ECU was able to determine that NSC does expect the last day of term and the award date to match. Campus stakeholders were notified that the historic practice was ending. Beginning with Fall 2025, the award date and end of term match. While the Records Office is confident much progress has been made, minor findings through 2026 are possible.
Finding number: 2025-001 Federal agency: U.S. Department of Education (“ED”) Programs: Federal Pell Program and Federal Direct Student Loans Assistance listing #’s: 84.063, 84.268 Award year: 2025 The College will be looking at making some business process changes to review files submitted to NSC (N...
Finding number: 2025-001 Federal agency: U.S. Department of Education (“ED”) Programs: Federal Pell Program and Federal Direct Student Loans Assistance listing #’s: 84.063, 84.268 Award year: 2025 The College will be looking at making some business process changes to review files submitted to NSC (National Student Clearing House) and NSLDS (National Student Loan Data Service) on a monthly basis and perform monthly reconciliation between responsible offices to ensure students are accurately reported to ED/NSLDS. This new implementation will allow the College/Office to better verify each student’s enrollment status, status changes and related effective date visibility of reporting issues in the future. Timeline for Implementation of Corrective Action Plan Implemented Fall 2025 Contact Person: Alaina Marcotte, Director Financial Aid
Finding 2025-003 – Special Test and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance (See table in Management's Corrective Action Plan"). Condition/Context – Out of a population of approximately 1,000 student status changes a...
Finding 2025-003 – Special Test and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance (See table in Management's Corrective Action Plan"). Condition/Context – Out of a population of approximately 1,000 student status changes and 230 permanent address changes, a sample of 74 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2024-2025 academic year. Auditors believe this to be a representative sample although not a statistical sample. The enrollment information and withdrawal, address change, or graduation date per the University’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Corrective Action Plan: The finding has been addressed through staffing changes and scheduled reporting which took effect January 2026. The office of the University Registrar did not previously have a dedicated staff member to submit reports in a timely manner. With the departure of the Associate Registrar in April 2025, the task fell to several staff members to share the responsibility along with their other tasks. The office currently has an assistant registrar as well as a transcript evaluator who share the responsibility and submit reports once every 30 days, with the exception of winter reporting, which is on a different schedule due to breaks. Internal controls have been revised to check conferral dates prior to submitting the enrollment report for the Main Campus. Name of Contact Person: Julie Khella, University Registrar at jkhella@laverne.edu Projected Completion Date: This was corrected as of March 22, 2026
FINDING 2025-002 – Special Tests and Provisions – Cash Management: Significant Deficiency in Internal Control over Compliance (See table in "Management's Corrective Action Plan"). Condition/Context – The University made 48 draws for various student financial assistance cluster programs. Auditors sel...
FINDING 2025-002 – Special Tests and Provisions – Cash Management: Significant Deficiency in Internal Control over Compliance (See table in "Management's Corrective Action Plan"). Condition/Context – The University made 48 draws for various student financial assistance cluster programs. Auditors selected a sample of 7 and believe this to be a representative sample; however, it was not a statistical sample; Corrective Action Plan: This was done due to the perceived understanding that the new Federal Administration indicated that all grants were at risk of being cancelled and that the G5 website would go dark. Due to the unique nature of the Federal Administration’s perceived announcement, the University would not handle this in the same manner, in the future. If for some reason they were to cancel any future grants, the University would endure the cancellation and close out the grant in the usual process, which is by reimbursement only. Name of Contact Person: Lori Gordien Case, Associate Vice President of Finance and Controller at lgordien@laverne.edu Projected Completion Date: This was corrected as of March 31, 2025.
FINDING 2025-001 – Special Tests and Provisions – Return of Title IV Funds: Significant Deficiency in Internal Control over Compliance; (See table in "Management's Corrective Action Plan"); Condition/Context – Auditors selected a sample of 20 students out of a population of 109 that were identified ...
FINDING 2025-001 – Special Tests and Provisions – Return of Title IV Funds: Significant Deficiency in Internal Control over Compliance; (See table in "Management's Corrective Action Plan"); Condition/Context – Auditors selected a sample of 20 students out of a population of 109 that were identified by the University as having received some federal assistance and withdrew from the University during the year under audit. Auditors believed this to be a representative sample of the population; however, it was not a statistical sample. Corrective Action Plan: The finding has been addressed through the implementation of our FY2024 Corrective Action Plan. The Office of Financial Aid has collaborated with the University Registrar to develop a comprehensive report identifying non-completed courses inclusive of all grade codes. This report is reviewed on the day following faculty submission of final grades for both semester and modular terms. Students subject to R2T4 processing are identified by the Associate Director of Compliance & Special Programs and subsequently assigned to a team of three Program Managers for COD processing. Timely review of this report ensures that all required funds are returned within the 45-day regulatory timeframe. Internal controls have been revised to include a secondary review of all processed R2T4’s. Additionally, an internal control document will be established to demonstrate that R2T4 calculations were reviewed for accuracy and completeness. Name of Contact Person: Laura Evans, Director of Financial Aid at levans2@laverne.edu Projected Completion Date: This was corrected as of March 22, 2026
Department: Health and Human Services Administrative and Financial Services Title: Internal control over Foster Care and Adoption Assistance cash management needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The DHHS Financial Service Center will update...
Department: Health and Human Services Administrative and Financial Services Title: Internal control over Foster Care and Adoption Assistance cash management needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The DHHS Financial Service Center will update the IV-E cash on hand analysis to ensure the cash balances are tracked separately by each of the following Title IV-E programs: Foster Care, Adoption Assistance, Prevention Program and Guardianship Assistance. Completion Date: March 31, 2026 Agency Contact: Sarah Gove, Director, DHHS Service Center, DAFS, 207-458-6626
Department: Health and Human Services Title: Internal control over Foster Care level of care assessments needs improvement Questioned Costs: Known: $3,003 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department will submit Katahdin system enhancements and Level...
Department: Health and Human Services Title: Internal control over Foster Care level of care assessments needs improvement Questioned Costs: Known: $3,003 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department will submit Katahdin system enhancements and Levels of Care (LOC) report updates, to shorten timeframes, and schedule LOC assessments earlier, in order to meet 90-day and 12-month deadlines. The Department will work with vendors to shorten timeframes, to ensure assessments are completed timely. The Department will date and finalize Policy draft for Levels of Care for Resource Homes Chapter 14 with the Policy and Training unit. Completion Date: Jun 30, 2026 (first and second items) and December 31, 2026 (third item) Agency Contact: Robert Blanchard, Associate Director, OCFS, DHHS, 207-624-7955
Student Financial Assistance Cluster – 84.063 – Federal Pell Program Recommendation: We recommend the University should return the overawarded amount of $924 to the US Department of Education and should review and strengthen internal controls over Pell Grant calculations and disbursements to prevent...
Student Financial Assistance Cluster – 84.063 – Federal Pell Program Recommendation: We recommend the University should return the overawarded amount of $924 to the US Department of Education and should review and strengthen internal controls over Pell Grant calculations and disbursements to prevent future over-awards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The institution will implement a recurring enrollment report for Pell-eligible students reflecting enrollment term and registered credits as of the date the report is run. The report will be reviewed weekly during summer terms and after census for fall and spring to identify enrollment changes impacting Pell eligibility. Names of the contact persons responsible for corrective action: Lauren Svanda, Director of Financial Aid Planned completion date for corrective action plan: 05/04/2026
Student Enrollment Status Reporting Errors See 2025-009 for the Corrective action Plan.
Student Enrollment Status Reporting Errors See 2025-009 for the Corrective action Plan.
Financial Assistance Disbursed in Excess of Student Eligibility Modified existing report to include the identification of students with dependent status and independent level loans in the absence of a Parent PLUS denial. Added weekly task to Loan Processing calendar to include the review of report. ...
Financial Assistance Disbursed in Excess of Student Eligibility Modified existing report to include the identification of students with dependent status and independent level loans in the absence of a Parent PLUS denial. Added weekly task to Loan Processing calendar to include the review of report. Corrective Action was Completed on: August 25, 2025.
No Internal Controls Over Student Enrollment Status Reporting See 2025-008 for the Corrective Action Plan.
No Internal Controls Over Student Enrollment Status Reporting See 2025-008 for the Corrective Action Plan.
No Internal Controls Over Student Enrollment Status Reporting See 2025-007 for the Corrective Action Plan.
No Internal Controls Over Student Enrollment Status Reporting See 2025-007 for the Corrective Action Plan.
Financial Assistance Disbursed in Excess of Student Eligibility In September and October 2025, the Director of Student Financial Aid reminded the team members of the mandatory process step which requires them to review each student’s loan history in the NSLDS (National Student Loan Data System) and ...
Financial Assistance Disbursed in Excess of Student Eligibility In September and October 2025, the Director of Student Financial Aid reminded the team members of the mandatory process step which requires them to review each student’s loan history in the NSLDS (National Student Loan Data System) and place a copy of the NSLDS history in the student’s financial aid file as evidence of their review. A review process to confirm compliance was implemented in the fall 2025 semester. An Assistant Director in the Office of Student Financial Aid is responsible for performing audits of our internal files to confirm that the NSLDS reviews are documented. The Assistant Director also provides remediation to any team member whose records are not in compliance. The University has already repaid the over-award amount. Corrective action was completed on: October 29, 2025.
Student Enrollment Status Reporting Errors See 2025-006 for the Corrective Action Plan.
Student Enrollment Status Reporting Errors See 2025-006 for the Corrective Action Plan.
No Internal Controls Over Student Enrollment Status Reporting See 2025-003 for the Corrective Action Plan.
No Internal Controls Over Student Enrollment Status Reporting See 2025-003 for the Corrective Action Plan.
Student Enrollment Status Reporting Errors Collaborate with UNCG Information Technology Services (ITS) to create an automated process to correctly report enrollment status changes with appropriate status dates to the National Student Loan Database System (NSLDS) via the National Clearinghouse (NSC) ...
Student Enrollment Status Reporting Errors Collaborate with UNCG Information Technology Services (ITS) to create an automated process to correctly report enrollment status changes with appropriate status dates to the National Student Loan Database System (NSLDS) via the National Clearinghouse (NSC) when a student adds, drops, or withdraws from one or more (but not all) courses. Develop written policies and procedures that detail how the automated processing reports data, how manual updates are made, how to respond to error reports, and when/how to test samples at NSC and NSLDS on a recurring basis to ensure the process is working as intended. The written policies and procedures will identify key positions within the University Registrar Office and Office of Financial Aid and Scholarships and what each position is responsible for including regularly testing enrollment reporting to ensure NSC and NSLDS are up to date based on the latest enrollment reporting file. Anticipated Completion Date: April 3, 2026.
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