Corrective Action Plans

Finding 370659 (2023-003)

Significant Deficiency 2023

MI

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

Condition: The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. There were three errors identified that attributed to this finding. 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) T...

Condition: The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. There were three errors identified that attributed to this finding. 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates Planned Corrective Action: The errors have been corrected and the university has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings as well as all required cash management compliance issues. Contact person responsible for corrective action: Brian Bell, Director Student Account Services Anticipated Completion Date: 10/31/2023

View Audit 292382

Finding 370658 (2023-002)

Material Weakness 2023

Central Michigan University

MI

Questioned Costs Student Financial Aid Material Weakness

Condition: The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. There were three errors that attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepanc...

Condition: The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. There were three errors that attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Planned Corrective Action: To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Accounts will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the university is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly. Contact person responsible for corrective action: Brian Bell, Director Student Account Services (errors 1 & 3); Sarah Kasabian-Larson, Director of Scholarships and Financial Aid (error 2) Anticipated Completion Date: 11/15/2023 for procedural changes. Implementation of the new financial aid system scheduled for the 2024-2025 academic year.

View Audit 292382 Questioned Costs: $1

Finding 370657 (2023-001)

Material Weakness 2023

Central Michigan University

MI

Student Financial Aid Material Weakness Reporting

Condition: The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not r...

Condition: The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The student withdrew and was reported but with an incorrect effective date. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Planned Corrective Action: Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted to between staff to better manage project time commitments and ensure accuracy. As of August 3, Fall 2022 and Spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021-2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for Fall 2023 semester including: • Date Last date of attendance is determined. • Date file is sent to Registrar’s. • Date Registrar’s reviews each student on list. • Date Registrar’s updates NSC and/or NSLDS. • Date final compliance review against mandated reporting timelines is completed. Registrar’s and Office of Scholarships & Financial Aid in collaboration with academic leadership initiated a Verification of Non-Participation process in Summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for Fall 2023 semester. Additionally, the university is implementing a new financial aid system for the 2024-2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting. Contact person responsible for corrective action: Keith J. Malkowski, Registrar and Brian Bell, Director Student Account Services. Anticipated Completion Date: Fall 2023 for actions implemented by the Registrar’s Office. Implementation of the new financial aid system scheduled for the 2024-2025 academic year.

View Audit 292382

Finding 370604 (2023-002)

Significant Deficiency 2023

Graceland University and Subsidiary

IA

Questioned Costs Student Financial Aid Special Tests & Provisions

Corrective Action Plan 2023-002: The University concurs with the finding and has provided corrective action through correcting the identified errors and adding additional review of the R2T4 calculations. Anticipated Completion Date: June 2023 Contact Person: Reta George, Director of Student Financ...

Corrective Action Plan 2023-002: The University concurs with the finding and has provided corrective action through correcting the identified errors and adding additional review of the R2T4 calculations. Anticipated Completion Date: June 2023 Contact Person: Reta George, Director of Student Financial Services

View Audit 292289 Questioned Costs: $1

Finding 370551 (2023-001)

Significant Deficiency 2023

Lakeland University and Affiliate

WI

Student Financial Aid Reporting Significant Deficiency

Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend that the University update its processes and procedures related to reviewing the information posted to NSLDS to ensure the accuracy of the data. Explanation of disagreement with...

Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend that the University update its processes and procedures related to reviewing the information posted to NSLDS to ensure the accuracy of the data. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will complete a review of all students who received Title IV aid to ensure enrollment data is accurate. Name(s) of the contact person(s) responsible for corrective action: Debra Buffington Planned completion date for corrective action plan: 06/30/2024

View Audit 292250

Finding 370536 (2023-001)

None 2023

Judson Univeristy, A Baptist Institution

IL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: To ensure timely returns of Title IV funds, the University will expand communication to all non-traditional faculty and adjuncts detailing the importance of taking weekly attendance and for timely notification to the Registrar's o...

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: To ensure timely returns of Title IV funds, the University will expand communication to all non-traditional faculty and adjuncts detailing the importance of taking weekly attendance and for timely notification to the Registrar's office when a student has been absent for 14 days. This communication will be disseminated through fall and spring faculty assembly, newly developed training specifically for adjunct faculty and directly from the non-traditional program director. In addition, the University will start to strictly enforce adjunct contracts which include payment following the timely weekly submission of attendance. Finally, the University will also investigate if the current attendance taking software, ELEARN, can send alerts to both the Registrar's office and Student Financial Aid when a student has been marked absent two consecutive times. Person Responsible for Corrective Action Plan: Sarah Taylor, VP of Business Affairs Anticipated Date of Completion: February 29, 2024

View Audit 292214

Finding 370532 (2023-002)

None 2023

Lenoir-Rhyne University

NC

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

Name of Responsible Individual: Jeremy Shreve, Vice President of Business & Finance. Corrective Action: The University recognized that while the two students who were not issued refunds timely were unique situations, there needs to be better checks and balances in place to ensure all credit balances...

Name of Responsible Individual: Jeremy Shreve, Vice President of Business & Finance. Corrective Action: The University recognized that while the two students who were not issued refunds timely were unique situations, there needs to be better checks and balances in place to ensure all credit balances are properly refunded to students within the 14-day required period. One of the late refunds was caused due to untimely posting of financial aid awards in the student accounts office, as it was not within a traditional awarding window. In response to this concern, the Director of Student Accounts will more frequently post financial aid awards on sudent accounts, once a week at a minimum. The other late refund was caused by a student who did not properly set up their eRefund, which caused the payment to not be issued properly through the bank. To address this issue, the Director of Student Accounts is working with the IT department to create a reporting mechanism to identify what students are proprly signed up for eRefunds and cross-check them against the eRefund payment list before sending. This will identify any student not properly set up for the eRefund. Additionally, the Controller's office has a reconciliation process wherein any eRefund that is not issued from the bank properly should be identified. Unfortunately, this reconcilation process has not been performed frequently enough to catch all instances. The Controller's office has changed that to be performed on a weekly basis to ensure all instances are caught in time to be rectified before the 14-day period is over. Anticipated Completion Date: 1/31/2024.

View Audit 292194

Finding 370528 (2023-001)

Significant Deficiency 2023

Lenoir-Rhyne University

NC

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Name of Responsible Individual: Jennu Wyatt, Assistant Provost for Undergraduate Education. Corrective Action: The University experienced some turnover in the Registrar's office at the end of the 2023 fiscal year-end. This turnover unfortunately was the catalyst for the group of students who did not...

Name of Responsible Individual: Jennu Wyatt, Assistant Provost for Undergraduate Education. Corrective Action: The University experienced some turnover in the Registrar's office at the end of the 2023 fiscal year-end. This turnover unfortunately was the catalyst for the group of students who did not have their status change reported timely to the NSLDS as the previously submitted status change report, which these students were included within, kicked back from the NSLDS with several errors. That was unbeknownst to the remaining employees in the Registrar's office, until a couple of months later, when the issue was finally identified and resolved. The University now has a new Assistant Registrar in place and is interviewing for the Registrar position currently. Additionally, the Assistant Provost for Undergraduate Education, who now is the direct supervisor of the Registrar, is being trained in many Registrar functions, including the NSLDS reporting. The Assistant Provost is now on the communications contact list for all NSLDS reporting, as is the Assistant Registrar, so that any future error reports will be seen by multiple people and addressed in a timely manner. Anticipated Completion Date: 11/30/2023.

View Audit 292194

Finding 370508 (2023-001)

Significant Deficiency 2023

Logan University

MO

Questioned Costs Student Financial Aid Special Tests & Provisions

Personnel Responsible for Corrective Action: Director of Financial Aid, Kerry Hallahan Anticipated Completion Date: October 2023 Corrective Action Plan: The calendar for 2023 - 2024 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. ...

Personnel Responsible for Corrective Action: Director of Financial Aid, Kerry Hallahan Anticipated Completion Date: October 2023 Corrective Action Plan: The calendar for 2023 - 2024 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. At the start of each trimester, the calendar will be reviewed to verify any break of 5 days or more are accounted for within the R2T4 calculation setup.

View Audit 292105 Questioned Costs: $1

Finding 370497 (2023-001)

Significant Deficiency 2023

John A Logan College, Community College District #530

IL

Special Tests & Provisions Student Financial Aid Reporting

Finding No. 2023-001: Controls Over Student Financial Assistance Special Tests and Provisions – Enrollment Reporting (Repeated from Finding No. 2022-001) Condition: During the compliance testing of “Special Tests and Provisions” requirements related to Enrollment Reporting, we noted the following...

Finding No. 2023-001: Controls Over Student Financial Assistance Special Tests and Provisions – Enrollment Reporting (Repeated from Finding No. 2022-001) Condition: During the compliance testing of “Special Tests and Provisions” requirements related to Enrollment Reporting, we noted the following exceptions: • Two (2) students were not reported within the 60 day requirement. Plan: Admissions and Records will no longer award degrees after a two-week grade period following each semester’s conferred date. All students who do not apply or do not meet the qualifications to grade on this date will be awarded at the end of the following term. A letter of completion may be provided to students who complete degree requirements during the course of a semester. Applicable programs have been notified of this change. In addition, the final Clearinghouse submission with degrees will be submitted and validated prior to any submissions for the next term. Additionally, the degree submission list posted to the Clearinghouse will be compared to the final graduate list generated in Institutional Research to ensure the lists match. Anticipated Date of Completion: December 2023 Name of Contact Person: Stephanie Hartford, Provost

View Audit 292081

Finding 370491 (2023-002)

Significant Deficiency 2023

Hamline University of Minnesota

MN

Student Financial Aid Reporting Significant Deficiency

Department of Education 2023-002 Student Financial Assistance – 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 b...

Department of Education 2023-002 Student Financial Assistance – 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 auditfinding. Action taken in response to finding: Auditors identified five students where the change in enrollment status was not reported in a timely manner. It was noted that we identified the status changes while there was a cybersecurity breach within the file transfer system used by the National Student Clearinghouse (NSC), our third-party servicer. As a result, our reporting was delayed. We received notice of the incident from the NSC on June 16, 2023. Our next planned transmission was scheduled for June 28. We postponed our regular reporting schedule for one week while we reset our secure FTP password with NSC, initialized our account in their updated system, and while our ITS security officer evaluated the risk. We ended up submitting the file to the NSC on July 5. As a result of this incident, we remain vigilant for external factors that may impact our reporting schedule. We will address them as quickly as possible to avoid reporting delays. Names of the contact persons responsible for corrective action: Gwenn Sherburne, Registrar Planned completion date for corrective action plan: By first reporting date for 2023-2024 academic year in early September 2023.

View Audit 292076

Finding 370430 (2023-002)

Significant Deficiency 2023

Bloomfield College

NJ

Student Financial Aid Reporting Significant Deficiency

Bloomfield College and Affiliates respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with t...

Bloomfield College and Affiliates respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 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 Department of Education 2023-002 Student Financial Assistance Cluster – Federal Assistance Listing Numbers 84.268 & 84.063 Recommendation: We recommend that the College strengthen its policies and procedures toensure that student disbursement records are submitted accurately to the COD within 15 dayof disbursements being made to students’ accounts, and that the College maintain clear evidence that a secondary review is performed to verify that the submission was made timelyAction taken in response to finding: The error was identified prior to the end of the award year and the student’s award was corrected. The award was posted and disbursed prior to the return of the revised ISIR into the system. To ensure that accurate information is being used for awards, the Financial Aid office will strengthen its process to review changes and updates to a student’s FASFA prior to disbursing funds. This will ensure that disbursements are submitted accurately to COD with 15 days of the disbursements being made to the student’s accounts. Immediate processing and policy changes with the staff have been implemented. Contact person responsible for corrective action: Quincina Littlejohn, Director of Financial Aid973-748-9000 ext. 1211 Planned completion date for corrective action plan: The corrective action date was December 2023. The new procedures were put into effect immediately.

View Audit 292012

Finding 370428 (2023-001)

Significant Deficiency 2023

Bloomfield College

NJ

Student Financial Aid Special Tests & Provisions Eligibility

Bloomfield College and Affiliates respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with t...

Bloomfield College and Affiliates respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 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 Department of Education 2023-001 Student Financial Assistance Cluster – Federal Assistance Listing Numbers 84.268 & 84.063 Recommendation: The College should strengthen policies and procedures to ensure that student status transmission reports are submitted accurately to the NSLDS at least every 60 days, or more often, as determined to be appropriate. The College also should ensure that student Published Program Length Measurements are listed in years and that the Published Program Lengths are calculated in years as recommended by the NSLDS Enrollment Reporting Guide so that the Published Program Length calculation is accurate to the true length of the program for each student. Action taken in response to finding: The College has updated its policies and procedures in overseeing submissions to NSLDS by the third-party servicer “National Student Clearinghouse.” The Registrar’s office, Enterprise Information Services, and the Financial Aid office will work together to ensure that relevant information is reported accurately and timely by “NSC” in accordance with applicable regulations. Contact persons responsible for corrective action: Aylin Solu-Brandon, University Registrar, 973-655-7525 Planned completion date for corrective action plan: We implemented the corrective action in January 2024. Following a discussion with the staff about the finding, new processing procedures were promptly implemented. The College will ensure that student Published Program Length Measurements are listed in years and that the published Program Lengths are calculated in years.

View Audit 292012

Finding 370426 (2023-001)

Significant Deficiency 2023

Reach University

CA

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

RE: Finding 2023-001 (Return to Title IV Calculation), Corrective Action Plan A. Comments on Findings and Recommendations: For seven of the twenty-one Return to Title IV (R2T4) calculation procedures tested, the auditors noted that the R2T4 was incorrectly calculated. Reach University is in concurre...

RE: Finding 2023-001 (Return to Title IV Calculation), Corrective Action Plan A. Comments on Findings and Recommendations: For seven of the twenty-one Return to Title IV (R2T4) calculation procedures tested, the auditors noted that the R2T4 was incorrectly calculated. Reach University is in concurrence with the findings and recommendations and has taken the following corrective actions described below to ensure future accuracy and compliance. B. Actions Taken or Planned: 1. Reach University’s Office of Financial Aid has corrected all Fall 2022 Return to Title IV (R2T4) calculations. Additional institutional credits have been awarded to the impacted students as compensation for the over-refunded amount of Pell Grant returned to Ed. 2. The Office of Financial Aid and the Office of the Registrar have immediately assumed the task and responsibility of establishing the University’s annual academic calendar. This will ensure correct term start/end dates, as well as scheduled breaks within each term, are clearly and accurately documented. 3. All R2T4 calculations are audited by the Director of Financial Aid on a bi-weekly basis for completeness and accuracy. Status of Prior Year Audit No compliance findings were noted in the prior year report. J. Vinny Vincent-Dunn Director of Financial Aid 317-556-4900 | vvincentdunn@reach.edu

View Audit 291994 Questioned Costs: $1

Finding 370421 (2023-001)

Significant Deficiency 2023

Pacific University

OR

Internal Control / Segregation of Duties Student Financial Aid Subrecipient Monitoring § 200.303 § 200.403

Pacific University acknowledges the importance of an effective control environment. University policies do require approval of all timesheets. Management will re-emphasize the importance of this key approval control and periodically review supervisor compliance (with follow-up on exceptions). The ap...

Pacific University acknowledges the importance of an effective control environment. University policies do require approval of all timesheets. Management will re-emphasize the importance of this key approval control and periodically review supervisor compliance (with follow-up on exceptions). The approval requirement will also be added to Pacific’s mandatory annual compliance training for supervisors.

View Audit 291993

Finding 370401 (2023-001)

Significant Deficiency 2023

St. Catherine University

MN

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 all status changes are updated with the appropriate timef...

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 all status changes are updated with the appropriate timeframe as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: When we learned that the procedures didn't accurately explain the terms that needed to be reported, we updated them. We will include students who graduated from the prior term as well as the current term when needed, to ensure all graduates are included. Name(s) of the contact person(s) responsible for corrective action: Kerri Vickers Planned completion date for corrective action plan: October 2023

View Audit 291976

Finding 370259 (2023-003)

None 2023

Albright College

PA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action Plan Registrar office will follow the established reporting cadence that Albright has committed to, which is reporting to the National Student Clearinghouse (NSC) at least every 30 days to ensure timely reporting to NSLDS. Name(s) of Contact Person(s) Responsible for Corrective A...

Corrective Action Plan Registrar office will follow the established reporting cadence that Albright has committed to, which is reporting to the National Student Clearinghouse (NSC) at least every 30 days to ensure timely reporting to NSLDS. Name(s) of Contact Person(s) Responsible for Corrective Action: John Smith, Registrar Anticipated Completion Date: FY2024

View Audit 291869

Finding 370237 (2023-001)

Significant Deficiency 2023

Curry College

MA

Student Financial Aid Reporting Significant Deficiency

Finding 2023-001 Enrollment Reporting: Contact person(s) responsible for corrective action: Stephanny Elias, Associate Vice President of Financial Aid Robert Loconto, Director of Financial Aid June Koukol, Registrar Anticipated completion date:February 2024 Context and Corrective Action: In th...

Finding 2023-001 Enrollment Reporting: Contact person(s) responsible for corrective action: Stephanny Elias, Associate Vice President of Financial Aid Robert Loconto, Director of Financial Aid June Koukol, Registrar Anticipated completion date:February 2024 Context and Corrective Action: In the final Spring 2023 enrollment certification to the National Student Clearinghouse (NSC), 11 students were identified not having been reported as graduated to NSC. Six of these students were brought to the attention of the Registrar’s Office by the Auditors in December 2023/January 2024. An internal review by the Registrar on January 22, 2024 revealed five additional students. The separate DegreeVerify transmission, which serves as a backup process and updates the graduation status for any student who did not get coded as such via the NSC enrollment transmission, also did not generate a graduated status for these students. The Registrar’s Office has concluded that this is the result of an error within the SOPLCCV Banner process when it was run for these students. This process is run during degree conferral and aligns curriculum information between the student’s academic record and the degree conferral record. The SOPLCCV process didn’t produce the intended result for the impacted students, and their degree records in Banner were manually updated to correct discrepancies that would normally be updated via the process. Unbeknownst at the time was that the initial discrepancy and subsequent manual update impacted the reporting of the degree conferral to NSC in the relevant transmission, due to a data mismatch between NSC’s curriculum information and the degree conferral information. The December 2023 degree conferral has since taken place, and the Registrar’s Office confirmed that the SOPLCCV process worked properly for all December graduates. The Registrar’s Office also manually checked each December graduate in NSC on January 22, 2024 and confirmed that all 56 December graduates with Fall 2023 enrollment were reported appropriately to NSC as graduated in the December degree transmission. The Registrar’s Office is consulting with Curry College ITS to develop a report to consolidate and display data from the text files generated via the Banner NSC transmission into a readable Excel format, to easily check and identify graduates and how they are being reported to NSC in the transmission. In the interim, the Registrar’s Office will continue to manually check each graduate in the NSC degree file to confirm that degree conferral is reported appropriately to NSC. This review will take place within two weeks of degree conferral, after the degree transmission has been processed by NSC.

View Audit 291830

Finding 370217 (2023-002)

Significant Deficiency 2023

Woodbury University

CA

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

Date: November 11, 2023 From: Verletta Jackson, Registrar To: Moss Adams Subject: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Item: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Def...

Date: November 11, 2023 From: Verletta Jackson, Registrar To: Moss Adams Subject: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Item: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Deficiency In Internal Control Over Compliance. Corrective Action: The University has updated the status of all students in our latest batch send. That includes and is not limited to all students selected In the Single Audit. Steps/Policies Implemented to avert problem: The process for reporting information to NSLDS through the Clearinghouse works efficiently. The problem in this case, is that the University has always had two individuals with access to the upload data into the Clearinghouse. When one of the individuals responsible for uploading's position was eliminated, authorization was not given to anyone else as a backup. So, when the then Registrar resigned, no one on-site was authorized to upload the already prepared "send". That issue has been resolved and there will always be, once again, two individuals with access to upload. Although the process to resolve this Issue was extremely timely, permission to access the Clearinghouse site was eventually provided. Contact Person: The Registrar, Verletta Jackson is the responsible person. Her contact information is, Verletta Jackson, email Verletta.Jackson@woodbury.edu, phone 818 252 5277. Anticipated Completion Date: Completed as of 10.15.2023

View Audit 291795

Finding 370216 (2023-002)

Significant Deficiency 2023

Lewis-Clark State College

ID

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

Student Financial Aid Cluster: Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the college implement a checklist to reference to ensure all required elements of the Perkins loan records are retained as required. Explanation of disagreement with audit find...

Student Financial Aid Cluster: Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the college implement a checklist to reference to ensure all required elements of the Perkins loan records are retained as required. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Reports from third-party servicer will be reviewed monthly and notifications of paid in full will be processed per requirements. A copy of the promissory note stamped paid in full will be retained according to recordkeeping requirements. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes Planned completion date for a corrective action plan: Immediate Implementation

View Audit 291793

Finding 370210 (2023-001)

Material Weakness 2023

Lewis-Clark State College

ID

Student Financial Aid Reporting Material Weakness

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Te...

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants– Assistance Listing No. 84.379 Nursing Student Loans – Assistance Listing No. 93.364 Recommendation: We recommend that the College work with its third-party servicer and implement procedures to ensure that enrollment data, changes in status, and effective dates within NSLDS are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Financial Aid Office has temporarily taken over the administration of this process due to personnel changes in the Registrar’s Office. Enrollment reports are scheduled to be submitted monthly. The data is reviewed at various intervals of the process by Registrar and Financial Aid staff and the reviews are documented. Corrections and updates are provided and submitted as required. Procedures will be updated to reflect all changes and validations. An internal audit will be conducted using the third-party Audit Guide and will be documented. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Soo Lee Bruce-Smith, Travis Osburn, Kim Tuschhoff, and John Bender Planned completion date for a corrective action plan: Immediate Implementation

View Audit 291793

Finding 370183 (2023-005)

Significant Deficiency 2023

Clarke University of Dubuque, Iowa

IA

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

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program 2022/2023 P063P201430 Special Tests & Provisions: Enrollment...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program 2022/2023 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control and Noncompliance Finding Summary: One instance was noted where the enrollment status reported to the National Student Clearing House was not the same as the student’s actual enrollment status. Responsible Individuals: Robert Hoover, Director of Financial Aid and Kristi Bagstad, Registrar, Registrar’s Office Corrective Action Plan: The Registrar’s office will review clearing house batch errors reports and the Financial Aid office will conduct quality sampling once a semester. Anticipated Completion Date: Commenced December 1, 2023

View Audit 291731

Finding 370180 (2023-004)

Significant Deficiency 2023

Clarke University of Dubuque, Iowa

IA

Special Tests & Provisions Student Financial Aid Significant Deficiency

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program 2022/2023 P063P201430 Special Tests & Provisions: ...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program 2022/2023 P063P201430 Special Tests & Provisions: Verification Significant Deficiency in Internal Control over Compliance Finding Summary: Four instances were identified where there was no documented control over student verification. Responsible Individuals: Robert Hoover, Director of Financial Aid and Sylma Fernandez, Assistant Director of Financial Aid Corrective Action Plan: With the recent filling of vacant positions, newer staff were being trained on these processes. As such, multiple reviews were occurring simultaneously and were not documented in their usual manner as they would occur outside phases of training. Now that staff have been trained, review processes are being documented to enhance the visibility of control practices. Anticipated Completion Date: Commenced November 1, 2023

View Audit 291731

Finding 370177 (2023-003)

Material Weakness 2023

Clarke University of Dubuque, Iowa

IA

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

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2022/2023 P063P201430 Special Tests & Provisio...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2022/2023 P063P201430 Special Tests & Provisions:– Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary: Eight instances were identified where there was no documented control over the return of Title IV calculation. Responsible Individuals: Robert Hoover, Director of Financial Aid and Sylma Fernandez, Assistant Director of Financial Aid Corrective Action Plan: With the recent filling of vacant positions, newer staff were being trained in these processes. As such, multiple reviews were occurring simultaneously and were not documented in their usual manner as they would occur outside phases of training. Now that staff have been trained, review processes are being documented to enhance the visibility of control practices. Anticipated Completion Date: Commenced November 1, 2023

View Audit 291731

Finding 370175 (2023-002)

Significant Deficiency 2023

Clarke University of Dubuque, Iowa

IA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.038 Federal Perkins Loan Program & #84.033 Work-Study Program 2022/2023 P063P201430 - 2021/2022 Finding Summary: Certain amounts within the FISAP filed during fiscal year 2022 FISAP were ...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.038 Federal Perkins Loan Program & #84.033 Work-Study Program 2022/2023 P063P201430 - 2021/2022 Finding Summary: Certain amounts within the FISAP filed during fiscal year 2022 FISAP were reported incorrectly in Part III, Section B, Line 13 and in Part VI, Section A, Lines 1-23 columns e & f. Responsible Individuals: Robert Hoover, Director of Financial Aid and Deb Theill, Student Accounts Loan Coordinator Corrective Action Plan: The Financial Aid and Loan offices will obtain review from a non preparer of the FISAP report before submittal. Anticipated Completion Date: Tami Lansing did an initial review on 10/16/2023, another review will also be performed before May 1, 2024.

View Audit 291731

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