Corrective Action Plans

Finding 504651 (2024-002)

Significant Deficiency 2024

CA

Student Financial Aid Eligibility Reporting

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The reason that R214 were done late/inaccurately was due to an employee who was new to the position and instead of seeking assistance in a timely manner, waited until the prior retired Director of Student accounts was...

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The reason that R214 were done late/inaccurately was due to an employee who was new to the position and instead of seeking assistance in a timely manner, waited until the prior retired Director of Student accounts was contracted in to assist. This employee was transferred from enrollment department oversight and then transferred to business office oversight mid-year. Neither department could provide the necessary management of this position and that is when they reached out to contract back the former Director of Student Accounts. Our only other trained R2T4 employee left LPU in Spring 24 and due to staffing challenges with FAFSA Simplification, we could not get someone new trained in time. We have been working with a consulting firm, JM Solutions, and with consultants' input, we are restructuring the financial aid and Student Accounts department to fall under one direct oversight. LPU created an Associate Vice President of Enrollment Services who oversees FinancialAid, Student Accounts and Registrar. Underthe Associate VP, there is a new Director of Student FinancialServices (this combined role is the Director of Financial aid and Student Accounts). Going forward R2T4 will be done on the COD system per consultants' recommendation. Currently the Director of Student Financial Services is being trained on R2T4, and they are seeking to hire a fulltime position of a Financial Aid processor who will be trained on R2T4 as well. For now, the Associate VP and Director of Student Financial Services will be working together to ensure R2T4 are completed according to regulations, with additional oversight by consultants throughout the academic year. Person Responsible for Corrective Action Plan: Amber Burnett, Associate Vice President of Enrollment Services and Angel Cavazos, Director of Student Financial Services Anticipated Date of Completion: At this time oversight and changes are in place for the R2T4 process

View Audit 327230

Finding 504604 (2024-002)

None 2024

Texas College

TX

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

Finding 2024-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs: We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. (a) The College had a difference in the F...

Finding 2024-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs: We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. (a) The College had a difference in the Federal Work-Study program, which was not reconciled to the general ledger. (b) One (1) out of sixty (60) students tested for verification was missing their parent’s tax return. Total questioned cost was $3,698. Auditor’s Recommendation – The College should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. Corrective Action – The College accepts the auditor’s recommendations. Following the receipt of the recommendation, College staff (the VP for Business and Finance, the VP for Student Affairs, and staff from the Financial Aid Office) were informed of the findings. Staff noted the unwillingness of a student to provide parent’s tax document for verification, which lead to audit finding. Business Office and Financial Aid staff were advised to review the reported variance with the Federal Work-Study program; the College will have the FWS variance reconciled prior to the physical “closing of its books”. The College has a process that it uses to reconcile accounts and has no immediate plans to change the process. Staff are reminded of the process; the VP for Business and Finance will become more active in reviewing reconciliations for accuracy.

View Audit 327190 Questioned Costs: $1

Finding 504576 (2024-001)

Significant Deficiency 2024

Youngstown State University

OH

Student Financial Aid Reporting Significant Deficiency

Youngstown State University respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The finding from the schedule of Federal Program Audit Findings is discussed below. The finding is numbered consistently with the number ...

Youngstown State University respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The finding from the schedule of Federal Program Audit Findings is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING – FEDERAL PROGRAM AUDIT FINDING SIGNIFICANT DEFICIENCY 2024-001 Assistance Listing, Federal Agency and Program Name – 84.063, 84.268, U.S. Department of Education, Student Financial Assistance Cluster - Federal Pell Grant Program, Federal Direct Student Loans Federal Award Identification Number and Year - 84.063 - P063P192025, P063P202025, P063P212025, P063P222025, P063P232025 - 84.268 - P268K222025, P268K232025, P268K242025 Recommendation: We recommend the University implement controls to ensure that all campus level detail and program level detail is being appropriately reported through National Student Clearinghouse (NSC) to National Student Loan Data System (NSLDS) to ensure accurate enrollment status changes are reported to NSLDS via NSC. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The University Registrar and Financial Aid Director investigated the issue and developed additional procedures. The University Registrar will continue to cross-check 15 currently enrolled students with the NSC monthly enrollment data submission. The Financial Aid Director will supply the University Registrar with an additional 15 currently enrolled students with financial aid to cross-check with the NSC monthly enrollment data submissions. The Financial Aid Director will cross-check both sample lists with NSLDS enrollment data for accuracy. Names of the contact people responsible for corrective action: Tysa Egleton, University Registrar and Melissa McKenney, Financial Aid Director Planned completion date for corrective action plan: November 1, 2024

View Audit 327162

Finding 504569 (2024-001)

None 2024

Roger Williams University

RI

Special Tests & Provisions Student Financial Aid Reporting

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2024 Award Year; U.S. Department of Education Criteria or Specific Requirement ...

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2024 Award Year; U.S. Department of Education Criteria or Specific Requirement When a student withdraws during a term, the effective date reported to the National Student Loan Data System (“NSLDS”) for the withdrawn status is the withdrawal date used by the institution in accordance with 34 CFR 668.22 (b) or (c). In the case of the student who completes a term and does not return for the next term, leaving the course of study incomplete, the effective date is the final day of the term in which the student was last enrolled. The effective date for a completion/graduation status is the date the school assigns to the completion/graduation. (NSLDS Enrollment Reporting Guide November 20, and 34 CFR 682.610.) Condition Four students with status changes, out of seven selected for testing, had the incorrect effective date reported to NSLDS. The dates reported to NSLDS were between 6 and 26 days later than the actual effective date of the student’s status change. Views of Responsible Officials and Planned Corrective Actions The University concurs with the finding. The University intends to report the actual effective date of the student status changes. Names of Contact Person Responsible for Correction Action: Gloria Arcia, Executive Vice President for Finance and Administration and Chief Financial Officer Anticipated Completion Date: September 24, 2024

View Audit 327156

Finding 504530 (2024-001)

Significant Deficiency 2024

University of the Cumberlands, Inc.

KY

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

2024-001 Significant Deficiency: Disbursement Notifications (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) The University did not include the estimated amount of disbursement in the Federal Direct Loan disbursement notifications. Name of Contact Person Management ag...

2024-001 Significant Deficiency: Disbursement Notifications (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) The University did not include the estimated amount of disbursement in the Federal Direct Loan disbursement notifications. Name of Contact Person Management agrees with finding 2024-001. When disbursement notifications were built for the 2023-24 award year, the calculated fields to notify students of the amount of aid being disbursed were not properly updated. Alex Campbell, Director of Financial Aid, and Kaitrin Parrett, Assistant Director of Financial Aid, are the responsible parties for the corrective action. Contact information for the responsible parties is alex.campbell@ucumberlands.edu (606) 539-5569 and kaitrin.parrett@ucumberlands.edu (606) 539-5591 Corrective Action Plan Upon identifying the deficiencies in meeting regulations for disbursement notifications, immediate corrective actions were undertaken. In collaboration with software engineers, the disbursement notification template was updated to notify students of the type of Federal Direct Loan, the date of disbursement, the amount of aid disbursed, and all other required information related to regulatory requirements. The Financial Aid Office tested and reviewed disbursement notifications for Direct Subsidized Loans, Direct Unsubsidized Loans, and Direct PLUS Loans across all student populations and confirmed that the notifications were updated and all necessary information was communicated to students before the disbursement of Fall 2024 Federal Direct Loans. In future aid years, disbursement notification templates will be internally reviewed and tested by the Director and Assistant Director of Financial Aid each semester before the disbursement of Federal Direct Loans to ensure continued compliance. Testing of the configurations for the disbursement notification template will be completed in our Student Information System’s sandbox environment. In this environment, staff will be able to simulate and disburse all Federal Direct Loans to ensure notification templates are properly set up before moving into the production tenant. Periodic reports will be generated in the production tenant to confirm that students received the appropriate disbursement notification based on their award type and disbursement date. Expected Completion Date This corrective action plan was implemented on August 1, 2024, before Fall 2024 aid disbursements began on August 30, 2024.

View Audit 327110

Finding 504481 (2024-001)

Significant Deficiency 2024

College of Southern Idaho

ID

Special Tests & Provisions Student Financial Aid Reporting

Finding: 2024-00 I Federal Agency Name: U.S. Department of Education Assistance Listing Number(s}: 84.007, 84.033, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely ...

Finding: 2024-00 I Federal Agency Name: U.S. Department of Education Assistance Listing Number(s}: 84.007, 84.033, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student's enrollment status and changes in those enrollment statuses, whether they report directly or via a third-party servicer. When an Institution is made aware of a change in a student's enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS. During the testing of compliance for Enrollment Reporting, there was I instance out of 60 students tested where the change in student's enrollment status was not updated in NSLDS within 60 days of the effective date of the change. There was 1 instance out of 60 students tested where the enrollment status per CSI records did not agree to the enrollment status that was certified in NSLDS. Responsible Individuals: Bethany Parmer, Office of the Registrar, and Larisa Alexander, Information Technology Staff Corrective Action Plan: As a corrective measure, we have assigned a single point of contact to manage the submission of dates to the Clearinghouse, which then feeds the data to NLDS. This process was implemented last year and has proven effective, as the individual in charge has developed significant expertise and improved our reporting accuracy. However, during our transition to the new student system, we discovered that incorrect data was being fed from Jenzabar, which caused the finding. CSI will no longer input dates into both systems. The data is submitted in one system, and the systems communicate with each other, ensuring consistency and preventing discrepancies in dates. The follow chart demonstrates the flow of information for how the CAP will occur.

View Audit 327020

Finding 504480 (2024-001)

None 2024

Capital University

OH

Student Financial Aid

Management acknowledges that there was an error in the amount of Pell awarded to a student. Capital University reviewed all Pell awards for 2023 – 2024 and discovered a total of 3 occurrences of a Pell Grant being under awarded totaling $4,159. Students impacted have been credited for any error in t...

Management acknowledges that there was an error in the amount of Pell awarded to a student. Capital University reviewed all Pell awards for 2023 – 2024 and discovered a total of 3 occurrences of a Pell Grant being under awarded totaling $4,159. Students impacted have been credited for any error in their initial award. The University is reconfiguring the Ellucian Colleague program to ensure that this error does not occur in the future.

View Audit 327017

Finding 504421 (2024-002)

Significant Deficiency 2024

Missouri Baptist University

MO

Student Financial Aid Subrecipient Monitoring Reporting

Student Status Changes The process of reporting enrollment to the NSLDS has historically been housed within the Student Financial Services department. The compliance issues with enrollment reporting during the prior award year were a result of having only one individual trained in transmitting our m...

Student Status Changes The process of reporting enrollment to the NSLDS has historically been housed within the Student Financial Services department. The compliance issues with enrollment reporting during the prior award year were a result of having only one individual trained in transmitting our monthly file to the National Student Clearinghouse. Over the past few months, staff from our Records Office have been receiving training on preparing enrollment reporting files for transmission to the National Student Clearinghouse. During the current award year, collaborative meetings have been scheduled to have the principal agent from the Records Office and the principal agent from the Student Financial Services department meet to transmit data files to the Clearinghouse. Subsequent meetings are scheduled within 24-48 hours of each file transmission date to ensure error reports posted to the Clearinghouse are resolved in a timely manner. Zach Greenlee Director, Student Financial Services Phone: 314-392-2398 Email: zach.greenlee@mobap.edu

View Audit 326979

Finding 504417 (2024-001)

Material Weakness 2024

Missouri Baptist University

MO

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

Return of Title IV Funds (R2T4) Due to the specialized skills and knowledge required for processing returning funds through the R2T4 process, Missouri Baptist University will be reassigning the responsibility for reviewing withdrawals within the Student Financial Services department to the Director ...

Return of Title IV Funds (R2T4) Due to the specialized skills and knowledge required for processing returning funds through the R2T4 process, Missouri Baptist University will be reassigning the responsibility for reviewing withdrawals within the Student Financial Services department to the Director of Student Financial Services. All withdrawals will be evaluated by the Director and all calculations using the R2T4 calculator available on the Common Origination and Disbursement (COD) system will be performed by the Director. Additional staff within the department will be tasked with verifying accuracy of returns to help provide exposure to the highly technical work of R2T4, thus providing training that will enable broader sharing of the responsibility in the future. An internal report has been created to give a daily summary of students who have withdrawn since the following day. This will complement the existing reporting structure which consists of individual withdrawal paperwork processed by our Records Department. Bi-weekly reports will be given to the Senior Vice President for Business Affairs to monitor compliance. Zach Greenlee Director, Student Financial Services Phone: 314-392-2398 Email: zach.greenlee@mobap.edu

View Audit 326979

Finding 504414 (2024-006)

Significant Deficiency 2024

Shiloh Village School District #85

IL

Questioned Costs Procurement, Suspension & Debarment Student Financial Aid

The District should only include actual costs, not budgeted costs, on the expenditure reports filed with the Illinois State Board of Education. The District should also ensure that the expenditure reports filed with the Illinois State Board of Education are reconciled with the general ledger account...

The District should only include actual costs, not budgeted costs, on the expenditure reports filed with the Illinois State Board of Education. The District should also ensure that the expenditure reports filed with the Illinois State Board of Education are reconciled with the general ledger accounts of the District prior to submission. The District will ensure that expenditure reports only include eligible expenditures going forward. The District will take the necessary steps to reconcile the expenditure reports with the general ledger accounts before submitting to the Illinois State Board of Education.

View Audit 326978 Questioned Costs: $1

Finding 504411 (2024-005)

Significant Deficiency 2024

Shiloh Village School District #85

IL

Reporting Student Financial Aid

The District should file timely quarterly expenditure reports to stay compliant with federal awards. The District will ensure that expenditure reports are timely filed going forward.

View Audit 326978

Finding 504328 (2024-001)

None 2024

Oklahoma Wesleyan University

OK

Student Financial Aid Matching / Level of Effort / Earmarking

FINDING 2024-001 – Notification of Loan Disbursements Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($5,702,366) Award Number: P268K242030 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: N/A Condition Found: The University could ...

FINDING 2024-001 – Notification of Loan Disbursements Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($5,702,366) Award Number: P268K242030 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: N/A Condition Found: The University could not provide documentation that the required loan disbursement notifications were made to the student at the time disbursement for the forty-one students who received Federal Direct Student Loans in our sample. This represented the entire population of students who received Federal Direct Student Loans in our sample. Corrective Action Plan: Management agrees with the auditors’ finding and their recommendation. The Financial Aid Office discovered the error in July 2024 before the audit began. Up to that point, the Financial Aid Office believed the software was automatically sending loan disbursement notification emails. The Financial Aid Office worked with the information technology staff to correct the software error. Loan disbursement notification emails are being sent timely as of August 2024. Anticipated Completion Date: The corrective action was completed in August 2024. Contact Person Shala LaTorraca, Director of Financial Aid 918-335-6260

View Audit 326881

Finding 504300 (2024-005)

Significant Deficiency 2024

University of Idaho

ID

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

Student Financial Assistance Cluster – Assistance Listing No. 84.268. Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all of the required elements outlined in the FSA handbook. Expla...

Student Financial Assistance Cluster – Assistance Listing No. 84.268. Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all of the required elements outlined in the FSA handbook. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We created a weekly report for all communications. We also reviewed the populations selection. Name(s) of the contact person(s) responsible for corrective action: Randi Croyle, Director of Financial Aid. Planned completion date for corrective action plan: 12/31/24

View Audit 326827

Finding 504296 (2024-003)

Significant Deficiency 2024

University of Idaho

ID

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

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

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063. Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We created a report to track the timing of reporting disbursements to COD. Currently we load the disbursement record to COD once a week. If there is an issue and the file is rejected it creates issues with timeliness. We have a meeting on 10/9/2024 to evaluate how we want to resolve the issue. Name(s) of the contact person(s) responsible for corrective action: Randi Croyle, Danial Carlos, and Brady Nelsen. Planned completion date for corrective action plan: December 2024

View Audit 326827

Finding 504292 (2024-004)

Significant Deficiency 2024

University of Idaho

ID

Questioned Costs Student Financial Aid Eligibility § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.007. Recommendation: We recommend the University review their FSEOG awarding policy and procedures to ensure FSEOG is awarded to students with the lowest expected family contributions. Explanation of disagreement with audit finding: T...

Student Financial Assistance Cluster – Assistance Listing No. 84.007. Recommendation: We recommend the University review their FSEOG awarding policy and procedures to ensure FSEOG is awarded to students with the lowest expected family contributions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Student Financial Aid updated our auto packaging policy. Name(s) of the contact person(s) responsible for corrective action: This was a part of our aid year rollover process and planning. Planned completion date for corrective action plan: April 2024

View Audit 326827 Questioned Costs: $1

Finding 504291 (2024-002)

Significant Deficiency 2024

University of Idaho

ID

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

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007,84.033. Recommendation: We recommend that the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported...

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007,84.033. Recommendation: We recommend that the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are adjusting our corrective action. Last year we tested several out of cycle enrollment adjustments each term to ensure our processes were working. We didn’t find any issues. This year we will be comparing all the students were not reported to the Clearinghouse with the list reported to the Clearinghouse to ensure all students who need to be reported are properly reported. Name(s) of the contact person(s) responsible for corrective action: Randi Croyle, Director of Financial Aid. Planned completion date for corrective action plan: We ran our first comparison on 9/19/2024 and we will be running every month we do the Clearinghouse reporting.

View Audit 326827

Finding 504290 (2024-001)

Significant Deficiency 2024

University of Idaho

ID

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

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007. Recommendation: CLA recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Explanation ...

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007. Recommendation: CLA recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University agrees with the auditors’ recommendations of corrective action needed to ensure unclaimed Title IV federal funds are resolved within 240 days of disbursement date. The University has reviewed existing processes and identified improvements that will be made to internal procedures to ensure proper compliance is met. Name(s) of the contact person(s) responsible for corrective action: Delora Shoop & Amanda Bauer. Planned completion date for corrective action plan: December 2024

View Audit 326827

Finding 504276 (2024-002)

Significant Deficiency 2024

College of Western Idaho

ID

Special Tests & Provisions Student Financial Aid Significant Deficiency

Finding 2024‐002 Federal Agency Name: Direct Program – Department of Education Assistance Listing Number: P063P237884, P268K247884, P033A239207, P007A239207 Program Name: Student Financial Assistance Cluster Finding Summary: The College implemented new software functionality that automated sen...

Finding 2024‐002 Federal Agency Name: Direct Program – Department of Education Assistance Listing Number: P063P237884, P268K247884, P033A239207, P007A239207 Program Name: Student Financial Assistance Cluster Finding Summary: The College implemented new software functionality that automated sending notifications to students upon loan disbursement. The notifications of student financial aid disbursements were not sent timely due to the process being ran in simulation mode and this was not immediately identified by the College staff. Students were notified of their financial disbursement when this error was noticed by the College staff during the fiscal year 2024, however it was not within the 30 days outlined above. The College was able to correct the process for the summer 2024 disbursements, in which the 30-day time frame was met. Corrective Action Plan: The Assistant Director of Financial Aid will automatically receive an emailed report of all disbursement notifications that are emailed students each time email notifications are processed. The Assistant Director of Financial Aid will run a communication verification report each week to ensure that all disbursed loans correspond to disbursement emails sent to students. Any missing emails will be sent within the required time frame and meetings will occur with the responsible staff person as needed. The Executive Director Financial Aid reviews this communication verification report each month. Responsible Individuals: Jeneé Snyder, Executive Director Financial Aid Michelle Haviland, Assistant Director Financial Aid Anticipated Completion Date: Change in control process implemented July 1, 2024.

View Audit 326811

Finding 504266 (2024-002)

Significant Deficiency 2024

Lewis-Clark State College

ID

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

Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing 84.038 Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal re...

Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing 84.038 Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The finding was isolated to less-than-half-time Pell recipients. These recipients will be processed through the auto-packing process and then will undergo a secondary manual review prior to disbursement. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes and John Bender Planned completion date for corrective action plan: Immediate Implementation

View Audit 326792

Finding 504260 (2024-001)

Significant Deficiency 2024

Lewis-Clark State College

ID

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Perkins Loan Program– Assistance Listing No. 84.038 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal ...

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Perkins Loan Program– Assistance Listing No. 84.038 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants– Assistance Listing No. 84.379 Nursing Student Loans – Assistance Listing No. 93.364 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office took over the administration of this process due to personnel changes in the Registrar’s Office this past year. During this time period, we have reduced the incidents from 114 to 13. Enrollment reports will continue to be submitted monthly. The data is reviewed at various intervals of the process by Registrar and Financial Aid staff and the reviews are documented. Corrections and updates are provided and submitted as required. Procedures will be updated to reflect all changes and validations. Additional focus will be on the reports which overlap semesters. Timelines will be reviewed and adjusted as determined necessary Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Soo Lee Bruce-Smith, Travis Osburn, Kim Tuschhoff and John Bender Planned completion date for corrective action plan: Immediate Implementation

View Audit 326792

Finding 504218 (2024-001)

Material Weakness 2024

North Greenville University

SC

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

Return of Title IV (R2T4) Calculations Planned Corrective Action: The financial aid office has developed a checklist that the aid administrators will use to determine if aid sources have been posted/disbursed to student accounts prior to completing R2T4 calculations. The Financial Aid Office will m...

Return of Title IV (R2T4) Calculations Planned Corrective Action: The financial aid office has developed a checklist that the aid administrators will use to determine if aid sources have been posted/disbursed to student accounts prior to completing R2T4 calculations. The Financial Aid Office will maintain the checklist record of this verification for audit purposes and to track compliance. The Senior Financial Aid Counselor will complete the R2T4 calculations and one of our Financial Aid Counselors will monitor the completion of all checklist records as part of a check and balance process. Person Responsible for Corrective Action Plan: Cindi Patterson, Director for Financial Aid Anticipated Date of Completion: 10/01/24

View Audit 326717 Questioned Costs: $1

Finding 504130 (2024-004)

None 2024

Northern Kentucky University

KY

Questioned Costs Student Financial Aid Eligibility

The University agrees with the auditor’s findings and recommendation. The following corrective action will be taken: The University will implement controls to ensure student’s aid is being packaged and awarded on the anticipated enrollment of the student, with correct corresponding EFC. The Office o...

The University agrees with the auditor’s findings and recommendation. The following corrective action will be taken: The University will implement controls to ensure student’s aid is being packaged and awarded on the anticipated enrollment of the student, with correct corresponding EFC. The Office of Student Financial Assistance will collaborate with IT to ensure proper training and review of packaging logic accurately reflects the students’ federal student aid eligibility. Anticipated Completion Date: December 31, 2024 Leah Stewart, Assistant Vice President, Enrollment Management

View Audit 326552 Questioned Costs: $1

Finding 504127 (2024-002)

Significant Deficiency 2024

Northern Kentucky University

KY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

The University agrees with the auditors' finding and recommendation. The following corrective action will be taken: The University Registrar will adhere to: Provisions of 34 CFR Section 685.309(b) will be followed when reporting to NSLDS. The University will develop and implement controls to ensure ...

The University agrees with the auditors' finding and recommendation. The following corrective action will be taken: The University Registrar will adhere to: Provisions of 34 CFR Section 685.309(b) will be followed when reporting to NSLDS. The University will develop and implement controls to ensure students’ classification based on actual allowable credit hours are being properly reported to NSLDS. Unofficial withdrawals will be monitored to ensure timely reporting to NSLDS. The University Registrar will work collaboratively with the Information Technology office to modify the enrollment report to identify students with external credits as well as students who stop attending to allow proper reporting to the NSLDS within the required 30 days. Anticipated Completion Date: December 31, 2024 Leah Stewart, Assistant Vice President, Enrollment Management

View Audit 326552

Finding 504120 (2024-001)

Significant Deficiency 2024

Northern Kentucky University

KY

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

Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the ...

Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the Assistant Vice President, Enrollment Management to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED. Anticipated Completion Date: December 31, 2024 Leah Stewart, Assistant Vice President, Enrollment Management

View Audit 326552 Questioned Costs: $1

Finding 504099 (2024-003)

Significant Deficiency 2024

University of Dallas

TX

Special Tests & Provisions Student Financial Aid Cash Management

Corrective Action Plan – The University ahs reviewed the requirements outlined in 34 CFR 668.164(e) and (f) and the Department of Education’s required submission. The University will comply with the requirements outline. It should be noted that the information required in the above referenced code w...

Corrective Action Plan – The University ahs reviewed the requirements outlined in 34 CFR 668.164(e) and (f) and the Department of Education’s required submission. The University will comply with the requirements outline. It should be noted that the information required in the above referenced code was available to the students on the University’s website at all times. Implementation – The University submitted the required information to the Department of Education on September 13, 2024. Responsible Official - Deborah Zimmerman, Controller

View Audit 326504

Corrective Action Plans

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