Corrective Action Plans

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2023-005 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: The Coll...
2023-005 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: The College did not timely and accurately complete refund calculations due to excluding one extra day in error for Thanksgiving break, which caused the total days to be off by one day. In review of the calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in 1 out of 4 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV returned was incorrectly calculated for 1 out of the population of 4 (25%) withdrawal calculations which resulted in only $32 being under refunded for one student in the sample. We consider this finding to be an instance of non-compliance in relation to Special Tests and Provisions and is not a repeat finding. Statistical sampling was not used in making sample selections. Corrective Action Plan: The Registrar's Office will review the school calendar in Common Origination and Disbursement Web Site before the financial aid office begins processing R2T4's for the school year. Responsible Person for Correction Action Plan: Hannah Masters (Executive Director of Financial Aid and Student Accounts) and Chayna Penney (Registrar) Implementation Date for Corrective Action Plan: 09/10/2024
View Audit 326482 Questioned Costs: $1
Finding 504082 (2023-004)
Significant Deficiency 2023
2023-004 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: The Coll...
2023-004 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 5 of the 37 students in the sample (13.5%). We consider this condition to be a significant deficiency in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-003. Statistical sampling was not used in making sample selections. Corrective Action Plan: During the 2022-23 school year, an employee who retired in May 2023 worked in the financial aid office. After retiring, a new position was created that is split between the Business Office and Financial Aid and Student Accounts office. This position now reviews student accounts weekly, and during that review they compare the date of disbursement to the student account and the date of disbursement in COD. Through this process, any mismatched dates are corrected and updated to COD. Due to the audit completion delay, our action plan for the previous audit could not be put into place before the year had already been completed. Below is the previous audit plan to show that it was implemented, however, timing meant implementation happened after the 2022-23 year had ended. The financial aid office is currently hiring for a new position that will oversee student accounts. Once this position is filled, we will implement our updated policy and procedure that requires review and collaboration to monitor COD disbursement date, financial aid software disbursement date and student billing statement disbursement date. This will ensure both financial aid staff and student accounts staff will confirm each date in all areas. Planned completion date for corrective action plan: 06/30/2023 Responsible Person for Correction Action Plan: Hannah Masters Implementation Date for Corrective Action Plan: June 2023
View Audit 326482 Questioned Costs: $1
2023-003 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: During o...
2023-003 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: During our testing of thirty-seven student files, we noted three individuals (8%) received a subsidized loan in excess of need. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Corrective Action Plan: During the 2022-23 school year, an employee who retired in May 2023 awarded all returning student institutional aid and federal aid. Hannah Masters, Executive Director of Financial Aid and Student Accounts, took over awarding all students (incoming and returning students). Starting in June 2023, Hannah awards all students based on enrollment status from Jenzabar 1 (Cottey's ERP) for returning students and Salesforce for incoming students. Upon census date, the Registrar sends an updated final report of student grade level and attempted credit hours. Hannah then reviews all student accounts manually and confirms the enrollment, grade level, and loan levels for each student. This ensures no student is under or over awarded for the term based on grade level or financial need. With the staffing changes, we are also now reviewing each package every time a FAFSA update is imported. This gives us another round of reviews to ensure students are not over or under awarded based on financial need. Responsible Person for Correction Action Plan: Hannah Masters Implementation Date for Corrective Action Plan: June 2023
View Audit 326482 Questioned Costs: $1
Recommendation: We recommend that the Organization implement procedures to document and maintain the documentation to support the controls over compliance are not only properly designed but are working. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. ...
Recommendation: We recommend that the Organization implement procedures to document and maintain the documentation to support the controls over compliance are not only properly designed but are working. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Waldorf has established procedures that instead of a second person simply reviewing the first person’s work, that we sign off and date at the time of review. If we cannot sign off in person, we will send an email for confirmation of the review for later documentation. We had the controls in place but lacked the proper documentation. We believe with implementing these items as our procedure will resolve this finding. Name(s) of the contact person(s) responsible for corrective action: Duane Polsdofer Planned completion date for corrective action plan: Immediately
Finding 503527 (2023-005)
Significant Deficiency 2023
Recommendation: We recommend that the Organization implement procedures to document and maintain the documentation to support the controls over compliance are not only properly designed but are working. Explanation of disagreement with audit finding: There is no disagreement with the audit finding....
Recommendation: We recommend that the Organization implement procedures to document and maintain the documentation to support the controls over compliance are not only properly designed but are working. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Waldorf reports enrollment data to NSLDS through National Clearinghouse (CH). Waldorf University just recently signed a contract with Jenzabar to adopt their platforms of JRM (Jenzabar Recruiting Management), J! (Jenzabar’s SIS system) and JFA (Jenzabar Financial Aid). This aid in all functions of the university from recruiting, enrollment, awarding, disbursing, academics, grading, and most all aspects of the university. We will no longer be tied to a homegrown system from our prior owners that was originally created for only a single university. We will have IT’s full support for their web-based software directly from the creators of the system. We believe having all the functions under one software platforms will greatly improve operations enabling the university to meet and exceed all guidelines. We are slated to begin with the JRM and JFA modules io late summer or early fall of 2025, with the full university on J1 by summer 2026. We are very excited to be able to finally resolve this finding. Name(s) of the contact person(s) responsible for corrective action: Duane Polsdofer Planned completion date for corrective action plan: Summer of 2026 (new system)
Finding 503519 (2023-003)
Significant Deficiency 2023
Recommendation: We recommend the College consider hiring a firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regul...
Recommendation: We recommend the College consider hiring a firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Waldorf University has contracted with a third-party for IT safeguards and a CPA firm that will help adhere to the most recent GLBA guidelines. Name(s) of the contact person(s) responsible for corrective action: Daisy Halvorson Planned completion date for corrective action plan: Fall of 2024
Finding 503004 (2023-002)
Material Weakness 2023
The fiscal department staff will compare the SACWIS placement cost report with billing. If any discrepancy occurs the fiscal department staff will confirm with the caseworker of the case for correct number of days. The fiscal department will verify the reimbursement report for accuracy.
The fiscal department staff will compare the SACWIS placement cost report with billing. If any discrepancy occurs the fiscal department staff will confirm with the caseworker of the case for correct number of days. The fiscal department will verify the reimbursement report for accuracy.
Finding 502724 (2023-008)
Significant Deficiency 2023
United States Department of Education 2023-008 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financ...
United States Department of Education 2023-008 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Auditors’ Recommendation: We recommend the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act that have not been completed and documented and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented a new SIS and Financial Aid processing system. The new systems are Jenzebar products and are fully compliant. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2024
Finding 502723 (2023-006)
Significant Deficiency 2023
United States Department of Education 2023-006 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Students tested in the Common Origination and Disbursement (COD) reporting were not properly reported based upon University documents, including disburseme...
United States Department of Education 2023-006 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Students tested in the Common Origination and Disbursement (COD) reporting were not properly reported based upon University documents, including disbursement dates and applied dates. Auditors’ Recommendation: We recommend that the entity strengthen its internal controls to ensure that all disbursement dates are reported to COD accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The previous SIS was subject to frequent interruptions which prevent timely data exchange with COD. Beginning with the 2024-2025 award year a new financial aid processing system was implemented. The new processing system is a more secure environment and hosted by Jenzabar for added compliance assurance. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2024
Finding 502722 (2023-005)
Significant Deficiency 2023
United States Department of Education 2023-005 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: The University is not reporting student information to the Clearinghouse. Students tested did not have their enrollment status properly reported to the Cle...
United States Department of Education 2023-005 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: The University is not reporting student information to the Clearinghouse. Students tested did not have their enrollment status properly reported to the Clearinghouse. Auditors’ Recommendation: We recommend that the entity strengthen its internal controls to ensure that all enrollment records are reported correctly and within the required time frame. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university uses HEAG Consultant Group for enrollment reporting to NSLDS. HEAG has been made aware of these findings and corrective actions have been requested. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: November 30, 2024
Finding 502721 (2023-004)
Significant Deficiency 2023
United States Department of Education 2023-004 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Student checks related to student refunds of Title IV federal financial aid was outstanding more than 240 days as of June 30, 2023. Auditors’ Recommendatio...
United States Department of Education 2023-004 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Student checks related to student refunds of Title IV federal financial aid was outstanding more than 240 days as of June 30, 2023. Auditors’ Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University is implementing financial internal controls policies and processes to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards and ensure compliance with the DOE. This includes procedures related to outstanding student refund checks over 240 days. Name(s) of the contact person(s) responsible for corrective action: E. ZeNai Savage, CPA, CFO and Executive VP of Finance and Administration
Finding 502720 (2023-003)
Significant Deficiency 2023
United States Department of Education 2023-003 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: The University submitted inaccurate data in its annual FISAP report. Auditors’ Recommendation: We recommend the applicable campus revise procedures to ens...
United States Department of Education 2023-003 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: The University submitted inaccurate data in its annual FISAP report. Auditors’ Recommendation: We recommend the applicable campus revise procedures to ensure that the record retention requirements are met and supporting documentation agrees to the FISAP, including a supervisory review by someone other than the preparer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Unduplicated Recipients for Ungrad/Dependent with salary range of $1000,000 and over was reported as one but should have been two. Completed FISAP reports are sent to the CFO for additional review prior to submission. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2024
Finding 2023-001: Inaccurate and Untimely Enrollment Status Reporting Comments on Finding and Recommendation(s): Statement of Concurrence: We concur with the finding of inaccurate and untimely reporting of enrollment status. The issue was due to human error from a previous employee who has been term...
Finding 2023-001: Inaccurate and Untimely Enrollment Status Reporting Comments on Finding and Recommendation(s): Statement of Concurrence: We concur with the finding of inaccurate and untimely reporting of enrollment status. The issue was due to human error from a previous employee who has been terminated as well as a misunderstanding of the policy. The transition period following the termination further compounded these issues. Actions Taken or Planned: 1. New Hire: We have already hired a new member for Financial Aid position since April 2023. This individual is responsible for ensuring the accuracy and timeliness of enrollment status reporting moving forward. 2. Staff Training: • All relevant personnel, including the newly hired staff, have been scheduled for ongoing training on financial aid compliance and the reporting process. • We will ensure that each employee is proficient in using the reporting systems (e.g., NSLDS, COD) and understands the required timelines for submission. 3. Process Review and Improvement: We are reviewing our existing processes to identify gaps and inefficiencies in the current reporting system. Once identified, these processes will be updated to ensure better data accuracy and timeliness. 4. Ongoing Monitoring and Compliance Audits: We will establish regular internal audits and monitoring protocols to ensure continuous compliance with reporting standards. Completion Date: Ongoing Dong-Hua Yang MD, PhD Title: Administrative Dean
The Institution reinforced its internal control procedures to ensure that the student disbursement date agrees with COD disbursement date back in 2023 when last year’s finding was disclosed. This single discrepancy was caused by an identified human error that has been addressed.
The Institution reinforced its internal control procedures to ensure that the student disbursement date agrees with COD disbursement date back in 2023 when last year’s finding was disclosed. This single discrepancy was caused by an identified human error that has been addressed.
This years Single Audit will be planned with enough time alongside the auditor in order to ensure submission before the due date. No later than October 15, 2024 we will already have engaged an auditor to perform and begin the Single Audit for the year ending September 30, 2024.
This years Single Audit will be planned with enough time alongside the auditor in order to ensure submission before the due date. No later than October 15, 2024 we will already have engaged an auditor to perform and begin the Single Audit for the year ending September 30, 2024.
Finding 502025 (2023-001)
Significant Deficiency 2023
The Finance and Business Department, with the Chief Information Officer, will need more training for procedures for cash drawdowns and expenditure's reconciliation per records and accounts on a timely basis.
The Finance and Business Department, with the Chief Information Officer, will need more training for procedures for cash drawdowns and expenditure's reconciliation per records and accounts on a timely basis.
RECOMMENDATION: MANAGEMENT SHOULD FORMALIZE A SYSTEM OF PROCEDURES AND CONTROLS TO ENSURE THE ORGANIZATION IS PROPERLY TRACKING FEDERAL AWARDS AND COMPLYING WITH ANY APPLICABLE REPORTING REQUIREMENTS AS IT RELATES TO FEDERAL AWARDS RECEIVED.
RECOMMENDATION: MANAGEMENT SHOULD FORMALIZE A SYSTEM OF PROCEDURES AND CONTROLS TO ENSURE THE ORGANIZATION IS PROPERLY TRACKING FEDERAL AWARDS AND COMPLYING WITH ANY APPLICABLE REPORTING REQUIREMENTS AS IT RELATES TO FEDERAL AWARDS RECEIVED.
RECOMMENDATION: MANAGEMENT SHOULD FORMALIZE A SYSTEM OF PROCEDURES AND CONTROLS TO ENSURE THE ORGANIZATION IS PROPERLY TRACKING FEDERAL AWARDS AND COMPLYING WITH ANY APPLICABLE REPORTING REQUIREMENTS AS IT RELATES TO FEDERAL AWARDS RECEIVED.
RECOMMENDATION: MANAGEMENT SHOULD FORMALIZE A SYSTEM OF PROCEDURES AND CONTROLS TO ENSURE THE ORGANIZATION IS PROPERLY TRACKING FEDERAL AWARDS AND COMPLYING WITH ANY APPLICABLE REPORTING REQUIREMENTS AS IT RELATES TO FEDERAL AWARDS RECEIVED.
Corrective Action Plan: The Methodist College Registrar has been working with NSC to get the college relinked to the correct college in their system, which was fixed 11/2023. The registrar redeveloped database query to pull the old data that had been deleted by NSC due to FERPA and began sending acc...
Corrective Action Plan: The Methodist College Registrar has been working with NSC to get the college relinked to the correct college in their system, which was fixed 11/2023. The registrar redeveloped database query to pull the old data that had been deleted by NSC due to FERPA and began sending accurate file submissions to NSC in June 2024. Files generated and submitted under the College’s new processes are taking roughly one week to process from initial submission, through error correction, and finalization. Contact Person(s): Justina Kirchgessner Anticipated Completion Date: End of 2024
Corrective Action Plan: In standing financial aid meetings, we will review Federal Loan limits and what our process/procedures are if a student is close to limits to insure, we don’t over award. Contact Person(s): Justina Kirchgessner Anticipated Completion Date: 2024
Corrective Action Plan: In standing financial aid meetings, we will review Federal Loan limits and what our process/procedures are if a student is close to limits to insure, we don’t over award. Contact Person(s): Justina Kirchgessner Anticipated Completion Date: 2024
View Audit 323383 Questioned Costs: $1
Identification on the Federal Program: Grantor: Department of Education Program Name: Federal Direct Student Loans Assistance Listing No.: 84.268 Views of responsible officials and planned corrective actions: The School’s Office of Student Financial Services has instituted comprehensive processes a...
Identification on the Federal Program: Grantor: Department of Education Program Name: Federal Direct Student Loans Assistance Listing No.: 84.268 Views of responsible officials and planned corrective actions: The School’s Office of Student Financial Services has instituted comprehensive processes and controls to ensure a timely review and submission of the FISAP, in accordance with the U.S. Department of Education’s FISAP instructions. The specific procedures will be documented in the School’s manual. With these protocols in place, we will adhere to the regulations set forth by the U.S. Department of Education. Name of responsible official: LaVerne Walker Director of Student Financial Services laverne.walker@mssm.edu Projected completion date: - September 26, 2024: Completed implementation of FISAP completion and signature submission. - October 7, 2024: Complete revision to procedure manual
The System returned the remainder of funds required. Firelands Regional Medical Center School of Nursing has implemented the following control to prevent this error in the future. The Financial Coordinator will submit a copy of the Return of Title IV funds report to the business office when retur...
The System returned the remainder of funds required. Firelands Regional Medical Center School of Nursing has implemented the following control to prevent this error in the future. The Financial Coordinator will submit a copy of the Return of Title IV funds report to the business office when returning funds. The business office will use this report to make sure the appropriate amount is posted to the student's account.
View Audit 323097 Questioned Costs: $1
Until August 2023, the College followed its regular schedule for updating students’ enrollments in the NSLDS enrollment reporting system. The updates were always performed on time every 30 days at the beginning of each month. The process began each month with NSLDS generating a list of students that...
Until August 2023, the College followed its regular schedule for updating students’ enrollments in the NSLDS enrollment reporting system. The updates were always performed on time every 30 days at the beginning of each month. The process began each month with NSLDS generating a list of students that needed to be updated. Only students who received Title IV funds appeared on the list. Our procedure to update the students in NSLDS was done manually, and it involved running a report on the NSLDS website to update each student individually with his or her corresponding enrollment status. Sometimes students did not appear in the NSLDS database during the semester that they started until months after they started. The timing of appearance in the database depended on when the student’s aid was disbursed. Once the student appeared in the database, the College would update the enrollment and indicate that the effective date of the status went back to a date before the student appeared on the database. The College believes this is the reason why it appears that it was late in reporting the two students cited, since they did not appear on the database at the beginning of the term when they started classes but rather at a later date. The College stopped reporting manually to NSLDS as of August 2023 and started reporting electronically via the Clearinghouse in September 2023. This process involves reporting on all students, not just those on the NSLDS database. For example, the auditors identified a student who was reported on time to the Clearinghouse pursuant to that new process, but who did not appear on the NSLDS database until almost 3 months later. The new process allowed the auditors to see the reporting trail. The College believes this same situation happened to the two students cited. Unfortunately, the manual process of reporting to NSLDS does not provide the same audit trail as does the new electronic process using the Clearinghouse. Now that the College is using the Clearinghouse process, this issue should not recur.
The Organization agrees with this finding and will strive to issue the required reports whenever possible.
The Organization agrees with this finding and will strive to issue the required reports whenever possible.
Turnover and vacancies in positions resulting in applications and petitions not being completed within 20 days of receipt. The Domestic Relations Department filled vacant positions through 2023. In response to the prior year finding, the Domestic Relations Department provided semi-annual training t...
Turnover and vacancies in positions resulting in applications and petitions not being completed within 20 days of receipt. The Domestic Relations Department filled vacant positions through 2023. In response to the prior year finding, the Domestic Relations Department provided semi-annual training to the Intake Unit staff in Case Initiation, record retention, time frame for conversion of applications/petitions to case files and file documentation beginning in November 2023.
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