Corrective Action Plans

Finding 389480 (2023-001)

Significant Deficiency 2023

Endicott College

MA

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

Finding Reference: 2023-001 Finding: During testing of student loan notifications, it was identified that one of forty students selected for test work did not receive a notification for three loan disbursements during the year. The item that was an exception described above did not result in changes...

Finding Reference: 2023-001 Finding: During testing of student loan notifications, it was identified that one of forty students selected for test work did not receive a notification for three loan disbursements during the year. The item that was an exception described above did not result in changes to the amounts awarded or disbursed to students by the College for the current fiscal year. The condition identified was the result of a student that selected to opt-out of College email notifications, which resulted in federal loan notifications to not be delivered. The College did not have adequate processes in place to ensure appropriately notification in accordance with federal regulations when a student selected to opt-out of receiving College communications. Endicott College Responsible Contact: Bryan Cain, Senior VP for Student and External Engagement Corrective Action Plan: This finding was the result of students being allowed to opt out of all notifications from Endicott College, which are initiated thru a notification system called EMMA. EMMA is the system of record used for notifying students of loan disbursements and as a result of students being able to opt out of all EMMA notifications this student was not notified of their loan disbursements. As a result of this finding the college has disabled the ability for students to be able to opt out of all EMMA notifications and thus being unable to opt out of student financial notifications such as loan disbursements. Anticipated Completion Date: February 2024

View Audit 300451

Finding 389387 (2023-007)

Significant Deficiency 2023

Urshan College

MO

Special Tests & Provisions Student Financial Aid Period of Performance

2023-007 Special Tests and Provisions – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagr...

2023-007 Special Tests and Provisions – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The director of financial aid works with the third-party servicer to ensure accurate student programs and program beginning dates reported to NSLDS. The financial aid office cross references program information within the student information system. Name(s) of the contact person(s) responsible for corrective action: Jason Benavides, Interim Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025

View Audit 300370

Finding 389385 (2023-006)

Significant Deficiency 2023

Urshan College

MO

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

2023-006 Special Tests and Provisions – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagr...

2023-006 Special Tests and Provisions – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The director of financial aid works with the third-party servicer to ensure accurate and timely enrollment updates to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Jason Benavides, Interim Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025

View Audit 300370

Finding 389383 (2023-005)

Significant Deficiency 2023

Urshan College

MO

Student Financial Aid Procurement, Suspension & Debarment Internal Control / Segregation of Duties

2023-005 Eligibility – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the a...

2023-005 Eligibility – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office designed a new process to coordinate with the academic office to review SAP status of students and ensure appropriate letters will be sent. Name(s) of the contact person(s) responsible for corrective action: Jason Benavides, Interim Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025

View Audit 300370

Finding 389382 (2023-004)

Significant Deficiency 2023

Urshan College

MO

Student Financial Aid Eligibility Reporting

2023-004 Eligibility – Assistance Listing No. 84.063 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to findi...

2023-004 Eligibility – Assistance Listing No. 84.063 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The director of financial aid works with the third-party servicer to ensure accurate and timely disbursement dates to COD. Name(s) of the contact person(s) responsible for corrective action: Jason Benavides, Interim Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025.

View Audit 300370

Finding 389378 (2023-006)

Significant Deficiency 2023

South Carolina State University

SC

Student Financial Aid Reporting Internal Control / Segregation of Duties

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in t...

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations. In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department. The University’s failure to reconcile the Fiscal Operations Report and Application to Participate to supporting documentation will be assessed by the new internal audit team. Corrective procedures and additional internal controls to ensure compliance with the special reporting requirements will be developed and/or modified as necessary. In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls to ensure compliance with the special reporting requirements. Anticipated Completion Date: June 30, 2024

View Audit 300369

Finding 389377 (2023-005)

Significant Deficiency 2023

South Carolina State University

SC

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

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in t...

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations. The University’s inability to provide evidence that a student’s Perkins Loan repayment schedule and another student’s Perkins Loan file were retained as required will be assessed by the new internal audit team. Corrective procedures and additional internal controls to ensure compliance with the special reporting requirements will be developed. In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls to ensure compliance with the special reporting requirements. Anticipated Completion Date: June 30, 2024

View Audit 300369

Finding 389367 (2023-002)

Significant Deficiency 2023

South Carolina State University

SC

Student Financial Aid Special Tests & Provisions Reporting

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in t...

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations. Management and implementation of current corrective plans are critical to the compliance efforts of the University: As stated in the previous corrective action plan the Registrar’s Office in coordination with the Information Technology Division has developed a “flag based” process to capture and monitor enrollment status changes. The implementation and proper reporting of these activities will be led the applicable team with oversight and assistance from the new internal auditing team. As this is a repeated finding, the University‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance/operation offices (Registrar’s Office and Academic Affairs Office). The University is requesting a report be filed on the status of this reporting requirement on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle. In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the applicable compliance requirements of enrollment reporting to ensure that all status changes are submitted to NSLDS within the required timeframe. Anticipated Completion Date: June 30, 2024

View Audit 300369

Finding 389363 (2023-001)

Significant Deficiency 2023

South Carolina State University

SC

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

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in t...

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies. In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department. Management and implementation of current corrective plans are critical to the compliance efforts of the University: The University has made the necessary changes to the staff and will continue to assess the efficiency of the review process to include, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University’s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. As this is a repeated finding, the University ‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance offices (Director of Financial Aid and Director of Transfer Students). The University is requesting a report be filed on the status of our transfer students on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle. In short, the University will enhance its oversight and management of the corrective action plans through the new internal audit unit until this matter has been resolved. Anticipated Completion Date: June 30, 2024

View Audit 300369

Finding 389359 (2023-001)

Significant Deficiency 2023

Molloy College

NY

Student Financial Aid Special Tests & Provisions Reporting

Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Finding 2023-001 – Special Tests and Provisions – Enrollment Reporting Name of contact person responsible for corrective action: Linda Albanese, Vice President Enrollment Management; lalbanese@molloy.edu; 516-323-4025 Molloy University u...

Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Finding 2023-001 – Special Tests and Provisions – Enrollment Reporting Name of contact person responsible for corrective action: Linda Albanese, Vice President Enrollment Management; lalbanese@molloy.edu; 516-323-4025 Molloy University understands the finding and has devised a process to ensure students who submit a request to withdraw which is effective after the completion of the current semester get processed manually in NSLDS once the semester has ended. To aid in this updated practice, a documented procedure has been established that provides a checklist of steps and collection of internal signatures to be completed for each student who indicates they wish to withdraw from the University. Additionally, we will be engaging a consultant to perform a compliance review with the US Department of Education for Enrollment Reporting. This will ensure that the withdrawal status is promptly provided within the required timeframe. Proposed completion date: February 20, 2024

View Audit 300357

Finding 389356 (2023-002)

Significant Deficiency 2023

Antioch University

OH

Special Tests & Provisions Student Financial Aid Period of Performance

Corrective Action Taken or Planned: The University has experienced changes in staffing for personnel involved in enrollment reporting and system irregularities with multiple programs with the National Clearing House. These inconsistencies have caused delays in processing and response to enrollment r...

Corrective Action Taken or Planned: The University has experienced changes in staffing for personnel involved in enrollment reporting and system irregularities with multiple programs with the National Clearing House. These inconsistencies have caused delays in processing and response to enrollment reporting changes. Antioch University has hired a new Director of Records Administration with a primary responsibility for NSLDS reporting. The University will implement a comprehensive training plan for new individuals and teams, including improved documentation of procedures, increased clarity regarding the process for the necessity of error resolution, and a review of system processing to help reduce errors in reporting and increase efficiency. In addition, internal reviews and control audits will be performed throughout the year to ensure accuracy in NSLDS reporting and alignment with the National Clearing House guidance. Person Responsible for Corrective Action: Maureen Heacock, the Registrar and Katy Stahl, Executive Director of Financial Aid & Scholarships are responsible for executing the corrective action plan. Anticipated Completion Date: Fiscal year 2024

View Audit 300356

Finding 389355 (2023-001)

Significant Deficiency 2023

Antioch University

OH

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action Taken or Planned: Starting with the 2024-2025 Award year, the Office of Financial Aid and Scholarships is undergoing an internal reorganization. The purpose of this is to provide a broader depth of knowledge and better dual control and compliance functions within the Office of Fina...

Corrective Action Taken or Planned: Starting with the 2024-2025 Award year, the Office of Financial Aid and Scholarships is undergoing an internal reorganization. The purpose of this is to provide a broader depth of knowledge and better dual control and compliance functions within the Office of Financial Aid and Scholarships. In the new reorganization structure, the FA Specialist will be responsible for performing the R2T4 Calculations, with their Supervisor, the Assistant Director of Financial Aid Operations, reviewing and approving the calculation. Once the calculation is completed, and signed off on by the Assistant Director, the FA Specialist will will complete and send the Financial Aid Transmittal Register (FATR) report and notify the Student Accounts Office so they can process the return of funds on through the Financial Aid Posting Register (FATP). Review of the Financial Aid Posting Register will be done by the FA Specialist to ensure the internal process to return funds is timely and posted to the Common Origination and Disbursement system accurately. A quarterly review and internal control audit of Title IV refund calculations will also be completed to ensure accuracy in system processing, days and break calculations, and adherence to Title IV regulations. In addition, the staff will have additional training throughout the year on Title IV compliance and refunds to ensure the University is compliant with all regulations. Person Responsible for Corrective Action: Katy Stahl, the Executive Director of Financial Aid & Scholarships, is responsible for the execution of the corrective action plan. Anticipated Completion Date: Fiscal year 2024

View Audit 300356

Finding 389281 (2023-001)

Significant Deficiency 2023

Hagerstown Community College

MD

Matching / Level of Effort / Earmarking Student Financial Aid Subrecipient Monitoring § 200.303

Hagerstown Community College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the num...

Hagerstown Community College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS- FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2023-001 NSLDS Enrollment Reporting Student Financial Aid Cluster-Assistance Listing No. 84.063, 84.268 Condition: During testing of enrollment status reporting, we noted that the incorrect enrollment status and effective date was reported to NSLDS. Recommendation: The College should evaluate their procedures and policies related to reporting status changes to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Cause-Enrollment Status Reporting: Hagerstown Community College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student enrollment status corrections were uploaded to NSC timely and correctly; however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate and timely update to the enrollment statuses in NSLDS. No review was completed to ensure the upload was completed in NSLDS. Cause for Effective Date Reporting - Hagerstown Community College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student effective date corrections were uploaded to NSC correctly; however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate update of the status effective date NSLDS. No review was completed to ensure the upload was completed in NSLDS. The following actions have been implemented to resolve the deficiencies: The Director of Financial Aid has reached out to NSC to determine the errors in the file transmissions. NSC responded back with the issues that need to be research by HCC's Student Financial Aid Office and Registrar's office. Both offices will collaborate to identify the error and develop procedures to minimize the error from happening again. HCC plans to review the reporting procedures for withdrawn and graduating students. NSC sent HCC a detailed explanation of what needs to be reviewed to make sure the correct information is transmitted. Name(s) of the contact person(s) responsible for corrective action: Dr. Charles M. Scheetz, Director of Financial Aid and W. Christopher Baer, Registrar Planned completion date for corrective action plan: Summer 2024

View Audit 300295

Finding 389279 (2023-003)

Material Weakness 2023

Saint Louis University

MO

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

Based on the recommendations outlined in this report, we are committed to enhancing our internal control process to ensure timely submission of Direct Loan and Pell Grant disbursement records to COD. This includes allocating necessary resources, providing additional training, and implementing robust...

Based on the recommendations outlined in this report, we are committed to enhancing our internal control process to ensure timely submission of Direct Loan and Pell Grant disbursement records to COD. This includes allocating necessary resources, providing additional training, and implementing robust monitoring and oversight mechanisms to address capacity constraints effectively and prevent future instances of noncompliance. Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above items by June 2024.

View Audit 300294

Finding 388573 (2023-006)

Significant Deficiency 2023

Mid-Atlantc Christian University

NC

Questioned Costs Student Financial Aid Reporting

2023-006 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, it was noted that the University incorrectly calculated institutional charges used in determining the amount of unearned aid to withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for ...

2023-006 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, it was noted that the University incorrectly calculated institutional charges used in determining the amount of unearned aid to withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary- The University has recently made improvements to the process of completing the return to Title IV calculations. This was achieved by providing additional training and workshops offered through the Department of Education. Furthermore, we have also developed a spreadsheet to assist with calculating the returned aid due to withdraw. We will utilize this information to thoroughly double-check our calculations before issuing official documentation. Anticipated Completion Date- July 1, 2024

View Audit 300264 Questioned Costs: $1

Finding 388572 (2023-005)

Significant Deficiency 2023

Mid-Atlantc Christian University

NC

Questioned Costs Student Financial Aid Reporting

2023-005 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, it was noted that the University used the incorrect sum of aid disbursed or disbursable to the student when applying the percentage earned in calculating the return to Title IV Funds upon student withdrawal. Name and Title ...

2023-005 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, it was noted that the University used the incorrect sum of aid disbursed or disbursable to the student when applying the percentage earned in calculating the return to Title IV Funds upon student withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary- The University has enhanced the process of completing return to Title IV calculations by incorporating additional training and workshops provided by the Department of Education. The financial aid office has designed a calendar that displays the attendance days from the first day of school to the last day of school, referring to the school's master calendar. This will be used as a cross-check of days when computing returns. The return calculations were one day off due to the misinterpretation of the semester's ending date. Anticipated Completion Date- July 1, 2024

View Audit 300264 Questioned Costs: $1

Finding 388571 (2023-004)

Significant Deficiency 2023

Mid-Atlantc Christian University

NC

Questioned Costs Student Financial Aid Reporting

2023-004 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, the University used the incorrect value for the total days in the students return to Title IV calculation. In completing the student's withdrawal, the institution used the incorrect amount of aid awarded/ disbursed for the ...

2023-004 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, the University used the incorrect value for the total days in the students return to Title IV calculation. In completing the student's withdrawal, the institution used the incorrect amount of aid awarded/ disbursed for the applicable period. The university incorrectly calculated the institutional charges within the return to Title IV calculation. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University improved the process for completing return to Title IV calculations by adding in additional training and workshops offered through the Department of Education. The financial aid office created a calendar showing days of attendance from the first day of school to the last using the school's master calendar as a reference. This will be used also as a double check of days when calculating returns. The dates used in the return calculations were off a day due to misreading the ending date of semester. Anticipated Completion Date- July 1, 2024

View Audit 300264 Questioned Costs: $1

Finding 388570 (2023-003)

Significant Deficiency 2023

Mid-Atlantc Christian University

NC

Student Financial Aid Reporting Significant Deficiency

2023-003 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, the University did not correctly report the student's enrollment status to National Student Loan Data System (NSLDS). The Department of Education had a waived window of errors from July 2022 to February 2023. Name and Title...

2023-003 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, the University did not correctly report the student's enrollment status to National Student Loan Data System (NSLDS). The Department of Education had a waived window of errors from July 2022 to February 2023. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University is continuing to improve communication between the Registrar's office, Financial Aid office, National Student Clearinghouse, and NSLDS with the goal of clear and correct reporting to NSLDS. Staff between the different departments have participated in training on enrollment reporting and how National Student Clearinghouse works directly with NSLDS. A monthly check list has also been created to make sure items are getting completed. Anticipated Completion Date- July 1, 2024

View Audit 300264

Finding 388569 (2023-002)

Material Weakness 2023

Mid-Atlantc Christian University

NC

Student Financial Aid Material Weakness Matching / Level of Effort / Earmarking

2023-002 Initial Fiscal Year End, 2023 Summary of Finding- During the 2023 audit, it was noted that the University's Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security progra...

2023-002 Initial Fiscal Year End, 2023 Summary of Finding- During the 2023 audit, it was noted that the University's Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University for the 2023 year. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University has updated its Gramm-Leach-Bliley Act Policy to be in accordance with the requirements, and we have also put in place adequate controls and practices to ensure that the policy is monitored effectively. Anticipated Completion Date- February 1, 2024

View Audit 300264

Finding 388544 (2023-005)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

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

East Stroudsburg University: The University will implement the following processes for monthly reconciliations and maintenance of documentation: Federal direct loan reconciliations will be prepared on a monthly basis by a member of the financial aid office. A log will be kept of notating the month r...

East Stroudsburg University: The University will implement the following processes for monthly reconciliations and maintenance of documentation: Federal direct loan reconciliations will be prepared on a monthly basis by a member of the financial aid office. A log will be kept of notating the month reconciled, date reconciled and preparer. The monthly reconciliations will be reviewed and approved by the Director of Financial Aid or the Assistant Director of Financial Aid. The approver will notate the date reviewed and their initial in the reconciliation log. Records of direct loan reconciliations will be retained for 5 years for auditing purposes. Reconciliation procedures will be documented, and employees will receive proper training and support on an on‐going basis.

View Audit 300242

Finding 388538 (2023-004)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

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

West Chester University: The WCU financial aid team will request the Pell Reconciliation report on COD bi-weekly or weekly basis depending on our disbursements. This report contains Pell awards that have disbursed in our student information system (SIS) and are not recorded at COD. The report will b...

West Chester University: The WCU financial aid team will request the Pell Reconciliation report on COD bi-weekly or weekly basis depending on our disbursements. This report contains Pell awards that have disbursed in our student information system (SIS) and are not recorded at COD. The report will be uploaded into our SIS within 1-2 days. When the report is loaded in our SIS, we will review each file to see which files did not transmit to COD. For the files that fail, we will correct the error/issue in our SIS and send the file out to COD in a timely manner for processing. After our Pell reconciliation is complete, we wll review our SIS and COD to ensure records agree between our SIS and COD (award amounts and processing dates). WCU is currently reviewing its policies and procedures around COD reporting and will ensure students' information is reported timely and accurately between our SIS and COD. WCU understands and agrees that the errors identified in the program review relate to Pell Grant disbursement reporting; and agrees, if a similar error related to Direct Loan disbursement reporting occurred, it could result in skewed interest calculation as students' interest accrues based on the disbursement date reported to COD. Going forward, WCU will review the SIS and COD data to ensure that all booked files link to the appropriate dates between our SIS and COD. Kutztown University: We reviewed our policies and procedures for COD reporting. A financial aid resource has implemented a sweep every fourteen days to ensure that compliance with the 15-day rule for PELL reporting is met consistently.

View Audit 300242

Finding 388537 (2023-003)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

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

East Stroudsburg University: The University Records’ Office will implement policy and procedures to ensure the enrollment effective date, and program enrollment effective date are in alignment between the University system, the National Student Clearinghouse and NSLDS. In the situation where a stude...

East Stroudsburg University: The University Records’ Office will implement policy and procedures to ensure the enrollment effective date, and program enrollment effective date are in alignment between the University system, the National Student Clearinghouse and NSLDS. In the situation where a student is withdrawing from the University or being administratively withdrawn due to an unofficial withdrawal, the University Records” Office will monitor student accounts to ensure that adjustments made to student records are not overridden by automated procedures. All reporting will be completed through the National Student Clearinghouse. Kutztown University: We re-evaluated policies and procedures to ensure compliance in reporting. We worked with the Registrar’s Office to rectify any errors in a timely fashion, as well as to detail and update our processes moving forward. A new resource was identified for this responsibility, who is continuously monitoring our submissions to ensure they are accepted in a timely manner. A financial aid resource works in conjunction with the Registrar’s Office to ensure errors are addressed timely to certify the accuracy of our reporting. Cheyney University: Cheyney University of Pennsylvania currently utilizes the National Student Clearinghouse as a third-party service provider for enrollment reporting and provides all enrollment data to National Student Clearinghouse. The National Student Clearinghouse only includes enrollment data for students on the enrollment roster they receive from the National Student Loan Data System (NSLDS). Students did not appear on the rosters, so the National Student Clearinghouse did not provide the enrollment data to NSLDS. Cheyney University learned that NSLDS did not receive students' enrollment status changes from NSC. As of Spring 2023, Cheyney University has implemented procedures to report enrollment status changes and last date of attendance for all Title IV recipients to NSLDS. Beginning August 2024, Cheyney University will begin utilizing BANNER to create the required enrollment file and transmit the information directly to NSLDS vis EdConnect or TDClient. Commonwealth University (Lock Haven): Controls have been put in place across multiple offices to ensure that program enrollment effective date and program enrollment status is reported correctly to NSLDS. Actions will include, but are not limited to, timely review of changes and checking data files prior to upload. West Chester University: Initial action has been taken to update the student's record with NSLDS. WCU will also add an additional check to our transmission process to review the file for this specific scenario. We will develop a report from our student information system to assist us in this review.

View Audit 300242

Finding 388536 (2023-002)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

Student Financial Aid Reporting Significant Deficiency § 200.303

West Chester University: We have recently modified our submission schedule to ensure we have adequate time to prepare our files, conduct our pre-submission checks, and resolve errors prior to the monthly exchange of data between the National Student Clearinghouse and NSLDS. We will continue to monit...

West Chester University: We have recently modified our submission schedule to ensure we have adequate time to prepare our files, conduct our pre-submission checks, and resolve errors prior to the monthly exchange of data between the National Student Clearinghouse and NSLDS. We will continue to monitor the time it takes to complete these tasks and make any necessary modifications to support timely reporting to NSLDS. East Stroudsburg University: The University Records’ Office will implement policy and procedures to ensure students’ enrollment statuses are being reported to NSLDS through the National Student Clearinghouse. Reporting will occur on a monthly basis by means of the University Records’ Office transmitting a file to the National Student Clearinghouse. The University Records’s Office will monitor student statuses in NSLDS by randomly sampling students reported through the National Student Clearinghouse to ensure the accuracy of data being reported to NSLDS. Kutztown University: We re-evaluated our reporting procedures and worked with the Registrar’s Office to further redefine our process(es). The Registrar’s Office submits monthly transmissions to NSC (National Student Clearinghouse), who in turn updates our information to NSLDS. A new resource was identified for this responsibility, who is continuously monitoring our submissions to ensure they are accepted in a timely manner. A financial aid resource works in conjunction with the Registrar’s Office to ensure errors are addressed timely to certify the accuracy of our reporting. Cheyney University: Cheyney University of Pennsylvania currently utilizes the National Student Clearinghouse as a third-party service provider for enrollment reporting and provides all enrollment data to NSC, believing that enrollment would be reported to NSLDS in compliance with federal regulations; unfortunately, NSC only includes enrollment data for students on the enrollment roster they receive from the National Student Loan Data System (NSLDS). Cheyney University is a Heightened Cash Monitoring 2 (HCM2) institution, and students' Title IV aid/disbursements are reported differently than advance pay institutions. Students did not appear on the rosters, so NSC did not provide the enrollment data to NSLDS. While investigating the issues with enrollment reporting for our HCM2 students, Cheyney University learned that NSLDS did not receive students' enrollment from NSC. As of Spring 2023, Cheyney University has implemented procedures to report enrollment for all Title IV recipients to NSLDS. Beginning August 2024, Cheyney University will begin utilizing BANNER to create the required enrollment file and transmit the information directly to NSLDS vis EdConnect or TDClient.

View Audit 300242

Finding 388533 (2023-006)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

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

Pennsylvania Western University: This finding resulted from reporting issues caused by the complexity of integration. These reporting issues have been corrected and now accurately identify students who need to be reviewed for official and unofficial withdrawals. Cheyney University: In July 2023, Ch...

Pennsylvania Western University: This finding resulted from reporting issues caused by the complexity of integration. These reporting issues have been corrected and now accurately identify students who need to be reviewed for official and unofficial withdrawals. Cheyney University: In July 2023, Cheyney University signed an agreement with Financial Aid Services, LLC (FAS) to outsource many of the financial aid related functions. Return to Title IV (R2T4) was one of the functions outsourced. The process to begin outsourcing was started in December 2023. In addition to outsourcing R2T4, the Office of the Registrar will provide the Office of Student Financial Services (SFS) with a list of students who are not registered for each semester. This distribution will culminate with census reporting to PASSHE and allow SFS to notify about repayment and Return to Title IV processes. For students who apply for graduation for a particular semester, a distribution of names, identification numbers, and anticipated graduation semester, will be provided to SFS so that they can complete their exit counseling procedures.

View Audit 300242

Finding 388527 (2023-002)

Significant Deficiency 2023

Wittenberg University

OH

Student Financial Aid Matching / Level of Effort / Earmarking

Corrective Action Planned: The Office of Financial Aid acknowledges that there have previously been a lack of controls in place when monitoring the R2T4 process. The staff member who was previously responsible for this process is no longer employed at Wittenberg University. The Director of Financia...

Corrective Action Planned: The Office of Financial Aid acknowledges that there have previously been a lack of controls in place when monitoring the R2T4 process. The staff member who was previously responsible for this process is no longer employed at Wittenberg University. The Director of Financial Aid who joined Wittenberg in a permanent capacity in May 2023 has been cross-training the new staff in the office to ensure a system of checks and balances on each of the federal aid processes. Wittenberg will also be using the R2T4 process within Ellucian Colleague to ensure that there is no need for additional manual calculations and/or data entry to be done. Person Responsible for Corrective Action: Sigrun Olafsdottir, Director of Financial Aid Anticipated Completion Date: Fiscal year 2024

View Audit 300226

Corrective Action Plans

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