Corrective Action Plans

Finding 504094 (2024-002)

Significant Deficiency 2024

TX

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Corrective Action Plan – The University has engaged the Chief Information Security Officer, IT Security personnel and the Chief Information Officer to review all elements of the Gramm-Leach Bliley Act requirements to ensure that the University complies with all required elements of the Act. A detail...

Corrective Action Plan – The University has engaged the Chief Information Security Officer, IT Security personnel and the Chief Information Officer to review all elements of the Gramm-Leach Bliley Act requirements to ensure that the University complies with all required elements of the Act. A detailed listing of all elements had been prepared; however, full assessment and implementation of remediation needed was not completed in a timely manner. Fifty five percent (55%) of the identified actions were completed at the time of the audit. Remaining items including a Written Information Security Plan were scheduled to be completed by February, 2025. Implementation – The responsible parties for implementation of the corrective action plan and ongoing compliance include the Chief Information Officer, Karl Horvath. As stated previously, over half of the needed items were completed prior to the audit, the Written Information Security Plan was completed by October 1, 2024 and the remaining items are due to be completed by February 28, 2025.

View Audit 326504

Finding 504092 (2024-001)

Material Weakness 2024

University of Dallas

TX

Special Tests & Provisions Student Financial Aid Reporting

Corrective Action Plan - Upon reflection of the term end date and subsequently the status change date, the Office of Registrar at the University of Dallas updated the term end date to the last date of educationally related activities more widely known as the last date of the final examinations for e...

Corrective Action Plan - Upon reflection of the term end date and subsequently the status change date, the Office of Registrar at the University of Dallas updated the term end date to the last date of educationally related activities more widely known as the last date of the final examinations for each relevant term. Upon consultation with the Office of the Provost at the University of Dallas and the appropriate Deans of the affected Colleges, the program length for the Master’s programs at the University of Dallas will be updated to three (3), for those programs who are at least 30 credit hours in length: which will meet a reasonable progression to such degree. The Office of Registrar at the University of Dallas will update all such programs for the University of Dallas. The Office of Registrar and the Office of Financial Aid explored reporting enrollment directly to the National Student Loan Data System and while such was initially promising, the Office of Financial Aid determined that such activity would be disruptive to the business practices of the University of Dallas given the work needed for the Financial Value Transparency and Gainful Employment reporting in which the National Student Loan Clearinghouse has served as an invaluable partner. This option may still be explored further if additional resources become available. The Office of the Registrar at the University of Dallas will split the graduation file sent to our third-party servicer, NSLC, so that the students from the Satish & Yasmin Gupta College of Business who are on a different calendar may be reported to NSLDS sooner which should assist in reporting those students on an earlier timeframe. The Office of Registrar at the University of Dallas will begin rolling grades the week after Add/Drop on a weekly basis of each term to reduce the timeframe for students who have withdrawn from a course to be reported to NSLDS. The Office of the Registrar at the University of Dallas will update the grading policy in Ellucian Banner to align any changes in grading policy for students who fail to attend course. The Office of Financial Aid will work with the Student Registrar to ensure such reporting is accurate by reviewing the set-up of such data points as Enrollment Effective Date, Enrollment Status, Term Begin Date, Term End Date and Award Completion Date. Implementation - The responsible parties include the Office of Registrar - Paula Brown, Registrar, the Office of Financial Aid, James Hubener, Director of Financial Aid, along with the staff of Information Technology led by Karl Horvath at the University of Dallas. Some updates to the status change dates or term end dates have already been recorded. Updates to the program length for Master’s programs will be made by November 2024. Implementation of internal Office of Registrar functions to assist in reporting for changes in grades and enrollment levels should be in place by November 30, 2024. Any change in the processing of the Graduated file from NSLC should be in place by the anticipated date of implementation of February 28, 2025. Full utilization of all changes by May 15, 2025 at the close of the Spring 2025 term.

View Audit 326504

Finding 504029 (2024-002)

Significant Deficiency 2024

Carleton College

MN

Student Financial Aid Reporting Significant Deficiency

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

Title: Student Financial Assistance Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell 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: Our office will create formal procedures for the Pell origination/disbursement process to ensure that our dates within the system and COD are aligned. Additionally, our new financial aid management system (FAMS) has the ability to track discrepant dates between COD and our FAMS and we will regularly use this feature to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Danielle Hayden Planned completion date for corrective action plan: November 1, 2024

View Audit 326409

Finding 504025 (2024-001)

Significant Deficiency 2024

Carleton College

MN

Student Financial Aid Reporting Significant Deficiency

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.0033, 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disa...

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.0033, 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Last year, we developed additional validation steps to ensure that the status of every student who has completed their program and graduated is accurately reflected at both the National Student Clearinghouse and NSLDS. These validation steps improved the accuracy of reporting for students included in the bulk reporting process. I will conduct a comprehensive review of our current reporting procedures to identify any gaps or inefficiencies. An additional staff member will be trained to report individual students to the National Student Clearinghouse in a timely manner, ensuring that any "one-off" updates are promptly completed. Name(s) of the contact person(s) responsible for corrective action: Theresa Rodriguez Planned completion date for corrective action plan: October 1, 2024

View Audit 326409

Finding 503949 (2024-001)

Significant Deficiency 2024

Drake University

IA

Student Financial Aid Internal Control / Segregation of Duties Reporting

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Expl...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial aid maintains a log of all Title IV withdrawals, and going forward it will provide access to this log to the Registrar’s Office and will notify the Associate Registrar each time a student is determined to be withdrawn for R2T4 purposes. This will ensure that the Financial Aid Office and the Registrar’s Office are aligned with regard to a student’s Title IV enrollment status. This will be particularly helpful to ensure compliance for students enrolled in modules, where a student could be considered withdrawn for a semester even if their transcript shows that credit was earned for all of their officially attempted credits. This compliance issue was discovered and remediated by Drake prior to the audit as part of our own internal review process. Upon each submission of the graduation data file to the National Student Clearinghouse, the Registrar’s Office will double-check the count of awarded degrees that appear on the submission file and compare it to the number of awarded degrees as reported by Drake’s student information system. Additionally, shortly after each file is submitted to the NSC, the Registrar’s Office will cross-check a sample of JD graduates against both the NSC database and the NSLDS database to ensure that the graduation status for graduates of the JD program is being accepted and processed by the NSC as expected, and that they are in turn properly reported to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Kevin Moenkhaus, Associate Registrar and Brandi Miller, Assistant Director of Financial Aid. Planned completion date for corrective action plan: September 1, 2024.

View Audit 326226

Finding 503661 (2024-003)

Significant Deficiency 2024

Dunwoody College of Technology

MN

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: Ther...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since uncovering this concern, the College is actively working with our third-party vendor (NSC) and our reporting team to resolve the technical issues that caused the errors. We have corrected the dates in NSLDS for the affected students. We have added an additional audit of data submitted to NSC and in NSLDS to rectify any technical errors within the required timeframe. Name of the contact person responsible for corrective action: Jaz Hofbauer, Registrar Planned completion date for corrective action plan: This process is in place for the 2024-2025 academic year.

View Audit 325860

Finding 503657 (2024-002)

Significant Deficiency 2024

Dunwoody College of Technology

MN

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College evaluate the transfer students’ status each semester. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: T...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College evaluate the transfer students’ status each semester. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The student affected by this deficiency gave erroneous information about attendance at another college in the same year as their intent to begin at Dunwoody. The processor failed to follow protocol to check for a transcript in NSLDS. The student had only used some of their loan eligibility at the previous institution in the fall semester, so we returned $5,250 in direct loan funds for this student. The student correctly retained the remaining $4,250 for the spring semester at Dunwoody. The total over award was not $9,500 but $5,250. Going forward, the financial aid counselors will be vigilant to search out every student in NSLDS before issuing the student any additional funding. There is now a check and balance in place that will catch anything the financial aid counselor might miss. Name of the contact person responsible for corrective action: Margaret Price, Director of Financial Aid Planned completion date for corrective action plan: This process is in place for the 2024-2025 academic year.

View Audit 325860 Questioned Costs: $1

Finding 503653 (2024-001)

Significant Deficiency 2024

Dunwoody College of Technology

MN

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College correct there mistake and review the amount of days scheduled in each break for next fiscal year. Explanation of disagreement with audit finding: There is no disagreement with the audi...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College correct there mistake and review the amount of days scheduled in each break for next fiscal year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The finding was caused by incorrectly calculating the Spring Break dates in the academic calendar. The former Director of Financial Aid accounted for the weekdays of break (M-F=5 days) instead of the required full week plus shouldering weekend dates (9 calendar days) as it should have been entered. This erroneous entry was not noticed or caught in a self-audit process. We have completed a 100% file review of withdrawn students and updated the break calculation to correct the error for this year, and moving forward we will conduct two levels of review when entering calculation parameters to ensure accuracy of break calculation. We have updated the affected students’ R2T4 calculations and sent the fund updates to COD on September 20th. The corrective action taken by the current Director of Financial Aid is to ensure there are two extra reviewers added to each future parameter rollover to make sure all dates are accurate in our processing software, as well as a second review of each completed R2T4. Name of the contact person responsible for corrective action: Margaret Price, Director of Financial Aid Planned completion date for corrective action plan: This new process is already in place for the 2024-2025 academic year.

View Audit 325860 Questioned Costs: $1

Finding 503622 (2024-001)

None 2024

Ringling College of Art and Design

FL

Student Financial Aid Subrecipient Monitoring Reporting

College Corrective Action Plan: ...

College Corrective Action Plan: Every 30 days, Ringling College of Art and Design reports updated student enrollment activity, encompassing attendance levels, graduation status, withdrawals, dropouts, and enrollment changes, to the National Student Loan Database System via the National Student Clearinghouse. Regrettably, during the 2023-24 academic year, an unforeseen error from the Clearinghouse resulted in the dissemination of incorrect enrollment statuses for a subset of our students. This oversight was beyond the Registrar's Office's knowledge, leading to an unintended delay in rectifying the reported statuses. We believe this Clearinghouse error was an isolated incident, having never occurred in any preceding academic year. The issue has been effectively resolved and should not recur in the future. Nevertheless, as a proactive measure, commencing with the 2024-25 academic year, the Financial Aid Office will collaborate with the Registrar's Office to review a representative sample of at least 10% of student records transmitted to the Clearinghouse. This review process will serve as an additional safeguard, ensuring the accuracy and timeliness of our reporting requirements. Lee Harrell Director of Financial Aid, Office: 941-359-7532, Cell: 941-928-9413

View Audit 325812

Finding 503536 (2024-001)

None 2024

University of St. Francis

IL

Questioned Costs Special Tests & Provisions Student Financial Aid

2024-001: Errors Relating to Return of Title IV Financial Aid - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264 Grant Period - Year Ended May 31, 2024 Condition Found During our return of Title IV Fund testing we noted that the Universit...

2024-001: Errors Relating to Return of Title IV Financial Aid - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264 Grant Period - Year Ended May 31, 2024 Condition Found During our return of Title IV Fund testing we noted that the University did not calculate or return Title IV for students who ceased attendance correctly for two students out of eleven. The University used the incorrect number of days for the total days in the period of enrollment when calculating the return of Title IV.We consider this to be an instance of non-compliance relating to the Special Tests and ProvisionsCompliance Requirement. Corrective Action Plan Moving forward, the financial aid team will implement internal controls: Marlon Jones, Director of Financial Aid will process the R2T4 using COD instead of Banner. So, Marlon will ensure that the dates for fall break (fall term)/spring break (spring term) are properly utilized within the R2T4 calculations, prior to the start of the terms. After Marlon’s initial process of completing the R2T4 calculation in COD, Erika Guzman, Associate Director, will check the completed R2T4 to ensure precise calculations. This new addition will ensure that two people are determining the accuracy of the R2T4’s, as well as ensuring that the breaks during the terms, are included. Responsible Person for Corrective Action Plan Marlon Jones Jr and Erika Guzman Implementation Date of Corrective Action Plan 9/23/2024

View Audit 325664 Questioned Costs: $1

Finding 503506 (2024-001)

None 2024

Mid-America Christian University

OK

Student Financial Aid Eligibility Reporting

Re: Response to References Number 2024-001 Student Financial Aid Cluster View of Responsible Officials: Comments on Finding and Recommendation The University agrees that the department did not accurately report the dates of two students' tested enrollment status changes. One date was off by two days...

Re: Response to References Number 2024-001 Student Financial Aid Cluster View of Responsible Officials: Comments on Finding and Recommendation The University agrees that the department did not accurately report the dates of two students' tested enrollment status changes. One date was off by two days, and the second one was off by ten days. This was caused by human error when updating the National Student Clearinghouse error report. Corrective Action Plan for References Number 2024-001 Student Financial Aid Cluster: The University Registrar provided additional training to the staff on the proper way to report status changes when a student withdraws to ensure the actual date of the withdrawal request is used instead of the final date of the term. This training occurred on 9.3.24 before the September National Student Clearing House (NSCH) was submitted. The University Registrar will review the error reports with the staff to ensure the dates are entered correctly before submission. Mid-America Christian University’s University Registrar, Stephanie Davidson, will be responsible for ensuring this corrective action plan is followed as outlined. Stephanie can be reached at stephanie.davidson@macu.edu or 405-692-3241

View Audit 325623

Finding 503499 (2024-002)

Significant Deficiency 2024

Northwestern College

IA

Student Financial Aid Reporting Significant Deficiency

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...

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: Starting in 2025-26 the College is transitioning to a new ERP, a more robust software system, that will correct this issue. However, in the meantime, the financial aid office will not rely on our current software to automatically match COD Disbursement dates with student account posting dates. The financial aid and business offices will communicate to ensure posting to student accounts are done on the same day as aid is disbursed. In addition, the financial aid and business offices will add a new process to compare COD reports with current software reports on a regular basis to look for any discrepancies. Any discrepancies found will be manually corrected on a timely basis. Name(s) of the contact person(s) responsible for corrective action: Eric Anderson, Director of Financial Aid Planned completion date for corrective action plan: June 30, 2025

View Audit 325620

Finding 503492 (2024-001)

Significant Deficiency 2024

Northwestern College

IA

Student Financial Aid Reporting Significant Deficiency

Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement wit...

Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The 2022-23 audit identified similar issues regarding NSLDS enrollment reporting. Following the 2022-23 audit, the College changed the submission dates to the NSC to allow more time for the NSC to timely report to the NSLDS. Upon further research following the 2023-24 audit, the College learned that this finding relates to manually reported graduates and withdrawn students. Graduates reported during the automated file submittal process were reported as graduating at end of term, while graduates reported manually were reported as graduating on the College’s actual commencement date (one day different than end of term). Going forward the Registrar will be consistent in reporting graduation dates using the end of term for all graduating students. As for the reporting of withdrawals, the Registrar will manually update the enrollment status and effective dates in NSLDS to ensure accurate and timely reporting in the 2024-25 fiscal year. Starting in 2025-26 the College is transitioning to a new ERP, a more robust software system, that will correct this issue. Name(s) of the contact person(s) responsible for corrective action: Austin Nyhof, Registrar Planned completion date for corrective action plan: June 30, 2025

View Audit 325620

Finding 503475 (2024-001)

Significant Deficiency 2024

Concordia University, Nebraska

NE

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the enrollment effective date reported to NSLDS on the cam...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the enrollment effective date reported to NSLDS on the campus and program level is aligning with the University. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Training on National Student Clearinghouse reporting steps when a non-returning student is processed after the first of term report has been submitted to National Student Clearinghouse. Review process for using end of term date, not Commencement ceremony date as award date. Name(s) of the contact person(s) responsible for corrective action: David L Kumm, Executive VP CFO/COO Planned completion date for corrective action plan: 10/31/2024

View Audit 325604

Finding 503368 (2024-001)

Significant Deficiency 2024

Warner Pacific University

OR

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements and is formally implemented. Explanation of disagreement with audit finding: There is no di...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements and is formally implemented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The currently-implemented IT procedures were documented in a written information security program (WISP). However, they had not been reviewed and approved during the year of the audit. A penetration test was completed in the Spring of 2024. The penetration testers were unable to gain access to any of the University’s information systems. A risk assessment and vulnerability assessment are scheduled to be completed before April 30, 2025. These actions should correct all significant deficiencies identified in section 2024-001. Name of the contact person responsible for corrective action: Douglas Wade, Executive Vice President and CFO Warner Pacific University 2219 SE 68th Ave Portland OR 97215 dswade@warnerpacific.edu Office Phone 503-517-1043 Cell Phone 661-706-8379 Planned completion date for corrective action plan: April 30, 2025

View Audit 325532

Finding 503359 (2024-001)

Significant Deficiency 2024

Williams Baptist University

AR

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

FINDING 2024-1 UNTIMELY RECONCILIATIONS Comments on Findings and Recommendations The management agent concurs with the auditor’s findings and recommendations. Actions Taken or Planned Management has assigned individuals responsible for performing monthly reconciliations.

View Audit 325521

Finding 503263 (2024-001)

None 2024

Francis Marion University

SC

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

COMPLIANCE FINDING 2024-001 Disbursements to or on behalf of Students September 25, 2024 Criteria: Before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receiv...

COMPLIANCE FINDING 2024-001 Disbursements to or on behalf of Students September 25, 2024 Criteria: Before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans (34 CRF 668.165(a)(1). Except in the case of a post-withdrawal disbursement made in accordance with § 668.22(a)(5), if an institution credits a student ledger account with Direct Loan, Federal Perkins Loan, or TEACH Grant program funds, the institution must notify the student or parent of (34 CFR 668.165(a)(2)) – (i)The anticipated date and amount of the disbursement; (ii)The student's or parent's right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACHGrant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary; and (iii)The procedures and time by which the student or parent must notify the institution that he or she wishes to cancelthe loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement. The institution must provide the notice described in paragraph (a)(2) of this section in writing (34 CFR 668.165(a)(3)) (i)No earlier than 30 days before, and no later than 30 days after, crediting the student's ledger account at theinstitution, if the institution obtains affirmative confirmation from the student under paragraph (a)(6)(i) of this section;or (ii)No earlier than 30 days before, and no later than seven days after, crediting the student's ledger account at theinstitution, if the institution does not obtain affirmative confirmation from the student under paragraph (a)(6)(i) of Effect: Noncompliance with certain requirements under 34 CFR 668.165(a). Corrective Action: The Office of Financial Assistance has established and implemented procedures that ensure students and parents receive the notifications relating to certain federal loans as required under 34 CFR 668.165(a). Specifically, the notifications will be made via electronic mail and include the anticipated date and amount of the disbursement; the recipients' right to cancel the loan or disbursement; and the procedures and time relating to the recipients' notification of cancellation. These notifications will occur within the required time frame resulting from the type of confirmation received from the student. This procedure will adequately address these requirements. Contact Person: Ashley Owens

View Audit 325326

Finding 503146 (2024-001)

Material Weakness 2024

Amridge University, Inc.

AL

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

Correction action University personnel corrected the records in NSLDS and Clearinghouse on July 26, 2024 that were identified in Finding 2024-001. Additionally, university personnel conducted a thorough review of all students to ensure the records in NSLDS properly reflected an accurate enrollment s...

Correction action University personnel corrected the records in NSLDS and Clearinghouse on July 26, 2024 that were identified in Finding 2024-001. Additionally, university personnel conducted a thorough review of all students to ensure the records in NSLDS properly reflected an accurate enrollment status. The university immediately (August 2024) implemented training for the newly appointed Interim Registrar on the importance of timely and accurate reporting of enrollment status changes and graduation status. This training was conducted in coordination with the Vice President of Student Services, the Director of Financial Aid, the Controller, and the Director of Information Technology. In addition to hands-on training provided by university personnel, online resources were utilized from NSLDS, Clearinghouse, and the United States Department of Education. The policies and procedures for enrollment reporting has been strengthened, and includes the following reporting schedule: a student roster schedule will be submitted every 30 days. The exceptions report will be reviewed immediately and will be corrected within 10 days. Within 15 days of the end of each semester, a list of graduated students will be submitted to NSLDS. Exceptions will be corrected immediately to ensure all records in NSLDS match the student’s record. The university is confident that the finding related to enrollment reporting has been resolved. Enrollment files are being submitted every 30 days. Summer 2024 completers graduated on August 9, 2024. These students were reported through Clearinghouse, exceptions were addressed, and enrollment statuses of “Graduated” show on NSLDS as certified on September 13, 2024. The schedule of enrollment and reporting and graduation reporting will ensure that the statuses will be accurate in NSLDS. Responsible Person Rose Mulkey, Interim Registrar Anticipated completion date Completed as of July 26, 2024.

View Audit 325158

Finding 503116 (2024-002)

Significant Deficiency 2024

Saint Martin's University

WA

Student Financial Aid Special Tests & Provisions Reporting

Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Controls over Compliance - Federal Assistance Listing Number 84.063, 84.268 Recommendation: The auditors recommend the University further educate and train those involved in the reporting of enrollment status ch...

Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Controls over Compliance - Federal Assistance Listing Number 84.063, 84.268 Recommendation: The auditors recommend the University further educate and train those involved in the reporting of enrollment status changes to the NSLDS. The auditors also recommend the University review our documented policies and procedures and ensure controls exist and are well documented in order to ensure enrollment data is reported timely and accurately to NSLDS. Action taken: The Director of Financial Aid will continue education on enrollment reporting requirements. The Director and the Registrar will continue to work together on enrollment reporting requirements. The Director of Financial Aid will now report withdrawals due to R2T4, as well as conferrals, to the National Student Loan Data System directly once the University receives notice of either withdrawal or completion of a degree. Weekly, withdrawals for R2T4 are monitored and reported and now SFA will report directly to NSLDS to avoid any lag time in relying on reporting to the Clearinghouse. At the end of each term, after the Registrar has conferred degrees, SFA will also acquire the list of students who have graduated and report their graduation status to NSLDS. Name of Responsible Party: Erin Schaffer Anticipated completion date: 9/30/2024

View Audit 325123

Finding 503110 (2024-001)

Significant Deficiency 2024

Saint Martin's University

WA

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

Gramm-Leach-Bliley Act – Student Information Security – Significant Deficiency in Internal Controls over Compliance – Federal Assistance Listing Number 84.063, 84.268, 84.007, 84.033, 84.379, 84.038 Recommendation: The auditors recommend the University review the compliance requirements and update o...

Gramm-Leach-Bliley Act – Student Information Security – Significant Deficiency in Internal Controls over Compliance – Federal Assistance Listing Number 84.063, 84.268, 84.007, 84.033, 84.379, 84.038 Recommendation: The auditors recommend the University review the compliance requirements and update our written policy to ensure that it addresses all the required elements. Action taken: The CIO, Mary Donahoo, worked in conjunction with prior CFO to create a timeline for implementation for the requirements of GLBA. The Information Technology Services (ITS) department had begun policy development pertaining to the Gramm-Leach- Bliley Act (GLBA) specific elements in 16 CFR 314.4 during fiscal year 2024 but was unable to complete all the required implementations. The ITS department implemented, during fiscal year 2024, improvements to cyber security and minor elements of GLBA, including multifactor authentication. The action plan anticipates completion of all elements of GLBA by the end of the calendar year. Name of Responsible Party: Mary Donahoo Anticipated completion date: 12/31/2024

View Audit 325123

Finding 503100 (2024-002)

Significant Deficiency 2024

Morrison Institute of Technology

IL

Reporting Student Financial Aid

Condition - Student enrollment reporting was not performed by the Institute after September 2023. Corrective Action Plan - The Financial Aid Officer will continue to pursue ongoing training through FSA, NASFAA and ISAC to ensure that all reporting is done in a timely manner as required by regulatio...

Condition - Student enrollment reporting was not performed by the Institute after September 2023. Corrective Action Plan - The Financial Aid Officer will continue to pursue ongoing training through FSA, NASFAA and ISAC to ensure that all reporting is done in a timely manner as required by regulations. Contact Person, Title and Phone Number - Chris Scott, President, (815)-772-7218, Ext. 212 Anticipated Completion Date - August 1, 2024

View Audit 325103

Finding 503096 (2024-001)

Significant Deficiency 2024

Morrison Institute of Technology

IL

Eligibility Student Financial Aid Reporting

Condition - The Institute had the following changes that have not been updated in the Officials section on their ECAR: • A Board Member was no longer serving the institution as of May 2021. • A Board Member was added to the Board in March 2024. • A Board Member was no longer serving the institutio...

Condition - The Institute had the following changes that have not been updated in the Officials section on their ECAR: • A Board Member was no longer serving the institution as of May 2021. • A Board Member was added to the Board in March 2024. • A Board Member was no longer serving the institution as of May 2024. • A Financial Aid Officer was no longer active at the institution as of September 2023. • A new Financial Aid Officer was active at the institution as of September 2023. Corrective Action Plan - The Institute will review current procedures and adjust accordingly to ensure timely ECAR updates. Contact Person, Title and Phone Number - Chris Scott, President, (815)-772-7218, Ext. 212 Anticipated Completion Date - August 1, 2024

View Audit 325103

Finding 503018 (2024-001)

Significant Deficiency 2024

Dean College

MA

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

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loans, Assistance Listing Number 84.268; May 31, 2024 Award Year; U.S. Department of Education Condition ...

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loans, Assistance Listing Number 84.268; May 31, 2024 Award Year; U.S. Department of Education Condition Of the 17 students selected for enrollment reporting testing, 4 students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. View of Responsible Officials and Planned Corrective Actions Effective with the 2023-2024 Academic Catalog year, Dean College implemented a leave of absence policy (LOA) and a medical leave of absence policy (MLOA). These are intended as a temporary interruption of a student’s program of study for a semester. In the case of an MLOA, the reason for the leave is for health reasons (physical, mental or emotional). Extensions of a leave may be granted on a semester-by-semester basis for up to two years. Students on LOA or MLOA must notify the College after the end of their semester’s leave to indicate if they are planning to return in the subsequent semester, if they want to extend their leave by a semester, or if they are withdrawing from the College. As noted in the catalog, from a financial and financial aid perspective, both types of leave (LOA, MLOA) are treated the same as a withdrawal and is reported as such to the National Student Clearinghouse. Medical withdrawals and voluntary withdrawals are reported as withdrawals. Dean College also has a medical withdrawal policy and a voluntary withdrawal policy. These are not temporary interruptions of a student’s studies with an intent to return but are full withdrawals and reported as such. Students who later decide that they do want to return to Dean College must complete the readmission application. In this situation, it appears that the internal code used to record students who were leaving for medical reasons triggered a leave of absence coding to the Clearinghouse, not a withdrawal code as intended by College policy. Dean College reviewed all processes related to leaves of absence, medical leave of absence, and withdrawals, including all coding, to ensure that this does not happen in the future. Coding updates have been implemented, and we will monitor students during the Fall 2024 semester to ensure they are reported appropriately. Responsible Officials: Colleen Crane Expected Completion Date: 8/9/2024

View Audit 324963

Finding 502668 (2024-001)

None 2024

Dallas Theological Seminary

TX

Reporting Student Financial Aid Eligibility

Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: The Registrar’s Office will add additional reporting for the non-standard term to ensure that student enrollment statuses are updated to NSLDS within the 60 day time frame for reporting. An additional chec...

Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: The Registrar’s Office will add additional reporting for the non-standard term to ensure that student enrollment statuses are updated to NSLDS within the 60 day time frame for reporting. An additional check of students that received loans and withdrew officially or unofficially will be done in NSLDS to ensure that dates were entered correctly within the system and transferred over correctly each semester. Person Responsible for Corrective Action Plan: Matthew Adams, Assistant Director of Academic Records and Registrar Anticipated Date of Completion: June 30, 2025

View Audit 324682

Finding 502653 (2024-001)

Significant Deficiency 2024

Trustees of Grinnell College

IA

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the enrollment effective date reported to NSLDS on the campus...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the enrollment effective date reported to NSLDS on the campus level is aligning with the College as well as the status changes are reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. The College utilizes a custom report for enrollment reporting to the National Student Clearinghouse (NSC), who then provides data to NSLDS. In recent years the custom report has required additional manual updates. Ellucian, who provides the Colleague system that the Office of the Registrar uses as their system of record, provides quarterly updates to the Colleague code. Each system update results in necessary review and insertion of the custom report into the Colleague process. The College’s Chief Information Officer has approved funding to contract with a NSC Specialist from Ellucian during Fall 2024 to review Grinnell’s enrollment reporting process and to determine what changes should be made within the Colleague system to make the enrollment reporting process less manual. This would improve the accuracy of reporting by eliminating the constant review and manual adjustments the current process requires. Name(s) of the contact person(s) responsible for corrective action: Jason Luedtke, Senior ERP Specialist, Information Technology Services Planned completion date for corrective action plan: Spring 2025.

View Audit 324653

Corrective Action Plans

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