Corrective Action Plans

Finding 486153 (2023-005)

Significant Deficiency 2023

Donnelly College

KS

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Contact Person: Stephani Berry, Director of Financial Aid Views of Responsible Officials and Planned Corrective Action: Donnelly College concurs with the finding. The Director of Financial Aid has implemented procedures to post aid in batches and to coordinate the timing of the postings with the Bus...

Contact Person: Stephani Berry, Director of Financial Aid Views of Responsible Officials and Planned Corrective Action: Donnelly College concurs with the finding. The Director of Financial Aid has implemented procedures to post aid in batches and to coordinate the timing of the postings with the Business Office. Financial Aid staff review documentation from each batch posted and compare the data to the awards posted on COD. Each month the Director reconciles her records to COD. Anticipated Completion Date: Completed

View Audit 318808

Finding 486021 (2023-002)

None 2023

Progressive Rehab of PA INC

PA

Procurement, Suspension & Debarment Student Financial Aid Reporting

The organization will ensure that financial records are maintained on a current basis, reconciled timely and audited within nine months after year end. Additional support has been put in place within the accounting department to records are current, reconciled timely and audit is completed within ni...

The organization will ensure that financial records are maintained on a current basis, reconciled timely and audited within nine months after year end. Additional support has been put in place within the accounting department to records are current, reconciled timely and audit is completed within nine months after year end.

View Audit 318711

Finding 485969 (2023-004)

Significant Deficiency 2023

Benjamin Franklin Cummings Institute of Technology

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding number: 2023-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2023 Corrective Action Plan: Franklin Cummings Tech will implement a process where both the Enrollment Submissions and the Graduation ...

Finding number: 2023-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2023 Corrective Action Plan: Franklin Cummings Tech will implement a process where both the Enrollment Submissions and the Graduation Submissions are reviewed after the file is submitted to the National Student Clearinghouse. • The File will be submitted no later than the last day of each month. • The Error Report will be reviewed, and corrections made no later than the 5th Day of the subsequent month. • For enrollment submissions, the Registrar will establish a monthly meeting with the Director of Financial Aid to occur no later than the 10th day of the month to review the NSLDS Reporting and the Enrollment Reporting (Reject Detail) reports from the Clearinghouse. • Regarding the degree report, the Registrar will review the Degree Verify Report from the Clearinghouse within seven days of submitting the Degree Verification Report to the Clearinghouse. • All errors will be corrected no later than the 15th day of the month. The registrar will review the Degree Error Reports from last year to ensure that students are being reported as graduates in a timely manner. This review of prior graduates will be completed by the last day of March. Timeline for Implementation of Corrective Action Plan: March 31, 2024 Contact Person: James Klasen, Registrar

View Audit 318688

Finding 485968 (2023-003)

Significant Deficiency 2023

Benjamin Franklin Cummings Institute of Technology

MA

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

Finding number: 2023-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2023 Corrective Action Plan: Franklin Cummings Tech has taken the following steps to establish internal control procedures to ensure t...

Finding number: 2023-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2023 Corrective Action Plan: Franklin Cummings Tech has taken the following steps to establish internal control procedures to ensure that R2T4 calculations are performed timely. • Additional training was completed with the Registrar’s Office to clarify the importance of notifying all official and unofficial withdrawals to the Office of Financial Aid and Student Accounts Office. • The Leadership Team met with and provided additional training to the Office of Financial Aid and Student Accounts Office to review the Return of Title IV Federal Student Aid Policy and the importance regarding the timeline for the institutions refund policy. • To ensure all unofficial withdrawals have been identified the Registrar’s Office will run an additional report, twice a month (2 nd and 4th Tuesday) during each semester, that spans the entire term. This report will be provided to the Financial Aid and Student Accounts Office. This step will assist in the assurance that all unofficial withdrawals have been captured and that there is adequate time to complete all R2T4 calculations and refunds timely. • An R2T4 calculation will be completed for every student, regardless of the date it was determined the student withdrew to confirm every student is refunded according to the institution's refund policy. Timeline for Implementation of Corrective Action Plan: May 1, 2024 Contact Person: Shani Wilkerson, Director of Financial Aid

View Audit 318688 Questioned Costs: $1

Finding 485967 (2023-002)

Significant Deficiency 2023

Benjamin Franklin Cummings Institute of Technology

MA

Student Financial Aid Matching / Level of Effort / Earmarking

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2023 Corrective Action Plan: The Registrar will provide the Financial Aid Office a Withdrawal Report. • Provided each Wednesday by 5:0...

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2023 Corrective Action Plan: The Registrar will provide the Financial Aid Office a Withdrawal Report. • Provided each Wednesday by 5:00 p.m. • The report will include Student ID, Date of Withdrawal and Withdrawal Reason • The report will be monitored weekly by the Director of Financial Aid (DOF) to ensure that all students have been worked through the R2T4 process regardless of withdrawal date. This control will also ensure that R2T4 calculations are completed in a timely manner. The DOF will request appropriate follow-up between the Registrar and FA Solutions if a student is held for processing for more than 10 days. Timeline for Implementation of Corrective Action Plan: May 1, 2024 Contact Person: Shani Wilkerson, Director of Financial Aid

View Audit 318688

Finding 485966 (2023-001)

Significant Deficiency 2023

Benjamin Franklin Cummings Institute of Technology

MA

Questioned Costs Procurement, Suspension & Debarment Student Financial Aid

Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.033, 84.063, 84.268 Award year: 2023 Corrective Action Plan: An in-depth review will be completed for each student who is designated with a SAP Status from th...

Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.033, 84.063, 84.268 Award year: 2023 Corrective Action Plan: An in-depth review will be completed for each student who is designated with a SAP Status from the Registrar before Federal Aid is disbursed. SAP designations will be kept as part of the student’s financial aid file from one semester to the next and this status will be reviewed before any Title IV Aid is disbursed. Timeline for Implementation of Corrective Action Plan: May 1, 2024 Contact Person: Shani Wilkerson, Director of Financial Aid

View Audit 318688 Questioned Costs: $1

Finding 485527 (2023-004)

Significant Deficiency 2023

Keystone College

PA

Student Financial Aid Reporting

Administration will implement appropriate controls and train staff to ensure compliance with cash management practices for future federal awards.

View Audit 318303

Finding 485421 (2023-002)

Significant Deficiency 2023

County of Butler

PA

Student Financial Aid Eligibility Internal Control / Segregation of Duties

Corrective Action Plan - Finding 2023-002 Internal Control over Eligibility Department of Health and Human Services Foster Care Title IV-E - ALN #93.658 and Adoption Assistance Title IV-E - ALN #93.659. The County has reimplemented the previously performed procedure of completion and a sign off of a...

Corrective Action Plan - Finding 2023-002 Internal Control over Eligibility Department of Health and Human Services Foster Care Title IV-E - ALN #93.658 and Adoption Assistance Title IV-E - ALN #93.659. The County has reimplemented the previously performed procedure of completion and a sign off of a checklist of the documents reviewed in the Tile IV-E eligibility file. This review will be performed by an independent employee. This will typically be the TANF eligibility employee. A check mark will be placed on the check list beside each document that is reviewed and will include the initials of the employee completing the review. Any questions or concerns will be directed back to the original employee that performed the initial verification. Anticipated Completion Date: August 9, 2024. Person Responsible for Corrective Action: William Kepple Financial Operations Officer Human Services Department County of Butler PO Box 1208 Butler, PA 16003-1208. 724-284-5120. wkepple@co.butler.pa.us

View Audit 318160

Finding 485329 (2023-002)

Significant Deficiency 2023

Scott County

MN

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

Foster Care Title IV-E – Assistance Listing No. 93.658 Recommendation: We recommend the County reviews its procedures for giving timely notice of an individual’s termination or resignation to other departments as well as ensuring departments are reviewing the information provided to granting agenci...

Foster Care Title IV-E – Assistance Listing No. 93.658 Recommendation: We recommend the County reviews its procedures for giving timely notice of an individual’s termination or resignation to other departments as well as ensuring departments are reviewing the information provided to granting agencies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will incorporate procedures and controls to ensure timely notice is given to other departments of an individual’s termination and the information provided to granting agencies is reviewed. Name of the contact person responsible for corrective action: Steven Jones (Budget Analyst) Planned completion date for corrective action plan: December 31, 2024.

View Audit 318076

Finding 485328 (2023-001)

Significant Deficiency 2023

Scott County

MN

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

Foster Care Title IV-E – Assistance Listing No. 93.658 Recommendation: We recommend the County reviews its procedures to ensure all casefile reviews are documented and all issues in the casefiles are followed up on and remedied properly. Explanation of disagreement with audit finding: There is no ...

Foster Care Title IV-E – Assistance Listing No. 93.658 Recommendation: We recommend the County reviews its procedures to ensure all casefile reviews are documented and all issues in the casefiles are followed up on and remedied properly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will incorporate procedures and controls to ensure all casefile reviews are documented and all issues in the casefiles are followed up on and remedied properly. Name of the contact person responsible for corrective action: Steven Jones (Budget Analyst) Planned completion date for corrective action plan: December 31, 2024.

View Audit 318076

Finding 485159 (2023-002)

Significant Deficiency 2023

Scott County

MN

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

Foster Care Title IV-E – Assistance Listing No. 93.658 Recommendation: We recommend the County reviews its procedures for giving timely notice of an individual’s termination or resignation to other departments as well as ensuring departments are reviewing the information provided to granting agenci...

Foster Care Title IV-E – Assistance Listing No. 93.658 Recommendation: We recommend the County reviews its procedures for giving timely notice of an individual’s termination or resignation to other departments as well as ensuring departments are reviewing the information provided to granting agencies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will incorporate procedures and controls to ensure timely notice is given to other departments of an individual’s termination and the information provided to granting agencies is reviewed. Name of the contact person responsible for corrective action: Steven Jones (Budget Analyst) Planned completion date for corrective action plan: December 31, 2024.

View Audit 317969

Finding 485158 (2023-001)

Significant Deficiency 2023

Scott County

MN

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

Foster Care Title IV-E – Assistance Listing No. 93.658 Recommendation: We recommend the County reviews its procedures to ensure all casefile reviews are documented and all issues in the casefiles are followed up on and remedied properly. Explanation of disagreement with audit finding: There is no ...

Foster Care Title IV-E – Assistance Listing No. 93.658 Recommendation: We recommend the County reviews its procedures to ensure all casefile reviews are documented and all issues in the casefiles are followed up on and remedied properly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will incorporate procedures and controls to ensure all casefile reviews are documented and all issues in the casefiles are followed up on and remedied properly. Name of the contact person responsible for corrective action: Steven Jones (Budget Analyst) Planned completion date for corrective action plan: December 31, 2024.

View Audit 317969

Finding 484569 (2023-067)

None 2023

State of Montana

MT

Internal Control / Segregation of Duties Student Financial Aid Allowable Costs / Cost Principles § 200.303 § 200.416

ALN: Various, Corrective Action Plan: Noncompliant Cost Allocation - DPHHS - The Montana Department of Public Health and Human Services has completed its cost allocation business improvement review, which looked at the department's cost pool allocation methodology, the creation of new pools, and t...

ALN: Various, Corrective Action Plan: Noncompliant Cost Allocation - DPHHS - The Montana Department of Public Health and Human Services has completed its cost allocation business improvement review, which looked at the department's cost pool allocation methodology, the creation of new pools, and the timeliness of updates and appropriateness to the Public Assistance Cost Allocation Plan (PACAP). All internal controls, processes and procedures were updated, training of department staff and training material was implemented, and new processes were effective as of quarter one state fiscal year 2024. The department has moved to quarterly PACAP submissions to assure that changes are caught timely. The department now sets the effective date of amended cost allocation plans to be the first day of the calendar quarter following the date of the amendment. Person(s) Responsible for Corrective Measures: Corinne Kyler, Administrator, Montana Department of Public Health and Human Services, Target Date: Completed

View Audit 317490

Finding 484383 (2023-051)

Material Weakness 2023

State of Montana

MT

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

ALN: 93.659, Corrective Action Plan: Reporting Controls and Compliance - Adoption Assistance - DPHHS - The Montana Department of Public Health and Human Services has enhanced internal control procedures to ensure the correct Federal Medical Assistance Percentage rate is included on the report. P...

ALN: 93.659, Corrective Action Plan: Reporting Controls and Compliance - Adoption Assistance - DPHHS - The Montana Department of Public Health and Human Services has enhanced internal control procedures to ensure the correct Federal Medical Assistance Percentage rate is included on the report. Person(s) Responsible for Corrective Measures: Nicole Grossberg, Administrator, Montana Department of Public Health and Human Services, Target Date: Completed

View Audit 317490

Finding 484216 (2023-019)

Material Weakness 2023

State of Montana

MT

Student Financial Aid Internal Control / Segregation of Duties Reporting § 200.303

ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 93.264, 93.364, 93.925, Corrective Action Plan: Internal Controls and Compliance - FISAP Reporting - MSU - The Montana State University (MSU) plans to take action about the Fiscal Operations Report and Application to Participate (FISAP) as follows: MSU...

ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 93.264, 93.364, 93.925, Corrective Action Plan: Internal Controls and Compliance - FISAP Reporting - MSU - The Montana State University (MSU) plans to take action about the Fiscal Operations Report and Application to Participate (FISAP) as follows: MSU-Bozeman – Financial Aid Services will return to consistently reporting the student count. As MSU-Bozeman is no longer awarding Perkins loans, the error was the result of inconsistent use of data fields to compensate for non-editable fields in the report. MSU-Billings – The Financial Aid office will implement a multiple-departmental review of information during the FISAP correction period and a review process for the completed FISAP before submission or during the FISAP correction period. The Associate Director of Financial Aid will review the full completed FISAP for any errors before submission. MSU-Northern – The Financial Aid office will put into place internal controls over FISAP preparation. Prior to submission, the FISAP report will be reviewed and signed off by a member of the Executive Team with a final review by the Chancellor. This will be put into place for the 2025-2026 award year. Records will be retained for seven years under record retention guidelines. Person(s) Responsible for Corrective Measures: James Broscheit, Director, Financial Aid Services, Montana State University - Bozeman Justin Beach, Director, Financial Aid and Scholarships, Montana State University - Billings Lourdes Caven, Director, Financial Aid, Montana State University - Northern, Target Date: 10/01/2024

View Audit 317490

Finding 484215 (2023-017)

Material Weakness 2023

State of Montana

MT

Student Financial Aid Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.303

ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 93.264, 93.364, 93.925, Corrective Action Plan: Internal Controls and Compliance - COA - The Montana State University (MSU) plans to take action as follows: MSU-Bozeman has complied since the 2022-23 academic year as indicated in the finding. No furthe...

ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 93.264, 93.364, 93.925, Corrective Action Plan: Internal Controls and Compliance - COA - The Montana State University (MSU) plans to take action as follows: MSU-Bozeman has complied since the 2022-23 academic year as indicated in the finding. No further action is needed. MSU-Billings requires a second review of the Cost of Attendance (COA) calculation and additional documentation before finalizing and creation in it accounting system. For the 2025-26 year, MSU-Billings is implementing the inclusion of a third reviewer within the Financial Aid office to review COA calculations before finalization. MSU Northern put into place internal controls over COA preparation for the 2023-24 award year. The university will have a review sheet that will be signed off by a Student Accounts representative, a member of the Executive Team, and the Financial Aid Director. After the signatures are in place, a copy will be sent to the Chancellor’s Office for final review. Records will be retained for seven years under approved record retention guidelines. Great Falls College-MSU has adjusted the Books and Supply and Other Living Expense components of its COA calculations. The adjustment for Other Living Expense was implemented for the 2023-24 school year, and the Books and Supplies adjustment has been implemented for 2024-25. Great Falls College-MSU has complied with the review of the COA by others not involved in creating the COA since the 2022-23 academic year as indicated in the finding. No further action is needed for this portion of the finding. Person(s) Responsible for Corrective Measures: James Broscheit, Director, Financial Aid Services, Montana State University - Bozeman Justin Beach, Director, Financial Aid and Scholarships, Montana State University - Billings Lourdes Caven, Director, Financial Aid, Montana State University - Northern Leah Habel, Director, Financial Aid, Great Falls College - MSU, Target Date: 12/31/2024

View Audit 317490

Finding 484214 (2023-025)

Material Weakness 2023

State of Montana

MT

Cash Management Student Financial Aid § 200.303

ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 93.264, 93.364, 93.925, Corrective Action Plan: Internal Controls and Compliance - Cash Management - MSU - Montana State University (MSU) plans to take action as follows: MSU-Bozeman. (1) For Federal Work Study and Federal Supplemental Education Oppo...

ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 93.264, 93.364, 93.925, Corrective Action Plan: Internal Controls and Compliance - Cash Management - MSU - Montana State University (MSU) plans to take action as follows: MSU-Bozeman. (1) For Federal Work Study and Federal Supplemental Education Opportunity Grant, MSU Financial Aid Services will work with University Business Services to remove these funds from the activity account. MSU-Bozeman will also return the interest earned in the accounts per prescribed method. The university does not believe the account balance is a result of excess cash draws, but rather a historical amount due to a system conversion and unreconciled funds; (2) Federal Direct Loan – the university conditionally concurs with the issue cited. University records show on the third day we had a positive cash balance, but by day four and within the seven-day tolerance, our cash balance was negative. As such, we do not believe additional corrective action will be necessary. MSU-Billings. The university will implement additional steps to improve the cash management process. It will run a daily report showing fund balances for all federal financial aid funds. Positive fund balances will be returned before the seventh day to comply with the regulation. MSU-Northern. The university's Business Services Office will run a daily report showing cash balances for all federal financial aid funds. If a positive balance is found that will not be distributed by the Financial Aid office within the allowable timeframe, a refund will be processed by the Business Services Office. Great Falls College MSU. Our business office will begin monitoring fund balances in all federal aid funds daily. Positive fund balances will be allowed for no more than four calendar days. At that point a return of funds will be processed by an accountant in the business office. Verification of return of funds will be completed the following day by the Controller. Person(s) Responsible for Corrective Measures: James Broscheit, Director, Financial Aid Services, Montana State University - Bozeman Justin Beach, Director, Financial Aid and Scholarships, Montana State University - Billings Lourdes Caven, Director, Financial Aid, Montana State University - Northern Lisa Ward, Controller, Great Falls College MSU, Target Date: 12/31/2024

View Audit 317490

Finding 484211 (2023-020)

Material Weakness 2023

State of Montana

MT

Student Financial Aid Internal Control / Segregation of Duties Reporting § 200.303

ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342, Corrective Action Plan: Internal Controls and Compliance - FISAP Reporting - UM - The University of Montana - Western, Montana Technological University, and Helena College have implemented their remediation plans for supporting documenta...

ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342, Corrective Action Plan: Internal Controls and Compliance - FISAP Reporting - UM - The University of Montana - Western, Montana Technological University, and Helena College have implemented their remediation plans for supporting documentation for each year of the Fiscal Operations Report and Application to Participate (FISAP) reporting as noted in the prior audit. Additionally, University of Montana - Western has trained its business services staff to process and document the information for future reporting; Montana Technological University conducts a third review of each FISAP; and Helena College reconciles additional accounting reports for quality assurance. Person(s) Responsible for Corrective Measures: Shauna Savage, Financial Aid Director, Montana Technological University Louise Driver, Financial Aid Director, University of Montana - Western Valerie Curtin, Financial Aid Director, Helena College, Target Date: Completed

View Audit 317490

Finding 484210 (2023-018)

Material Weakness 2023

State of Montana

MT

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

ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342, Corrective Action Plan: Internal Controls and Compliance - COA - UM - The University of Montana - Missoula, University of Montana - Western, and Helena College have implemented their remediation plan as noted in the prior audit, and will...

ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342, Corrective Action Plan: Internal Controls and Compliance - COA - UM - The University of Montana - Missoula, University of Montana - Western, and Helena College have implemented their remediation plan as noted in the prior audit, and will continue to implement internal controls to ensure the Cost of Attendance (COA) calculations are fully documented and supported. Beginning with the 2022-2023 academic year, UM Western has implemented a new process for maintaining thorough documentation to support COA calculations in which the Director of Financial Aid has taken responsibility. Person(s) Responsible for Corrective Measures: Ginger Lowry, Interim Financial Aid Director, University of Montana - Missoula Louise Driver, Financial Aid Director, University of Montana - Western Valerie Curtin, Financial Aid Director, Helena College, Target Date: Completed

View Audit 317490

Finding 484209 (2023-027)

Material Weakness 2023

State of Montana

MT

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

ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342, Corrective Action Plan: Internal Controls and Compliance - Enrollment Reporting - UM - The University of Montana - Missoula has implemented the remediation plan from the prior audit. Additional controls have also been implemented and an ...

ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342, Corrective Action Plan: Internal Controls and Compliance - Enrollment Reporting - UM - The University of Montana - Missoula has implemented the remediation plan from the prior audit. Additional controls have also been implemented and an Academic Program Manager, with a firm grasp on the accreditation standards surrounding code changes, was hired in early summer 2023. Person(s) Responsible for Corrective Measures: Maria Managold, Registrar, University of Montana - Missoula, Target Date: Completed

View Audit 317490

Finding 484208 (2023-026)

Material Weakness 2023

State of Montana

MT

Student Financial Aid Material Weakness Matching / Level of Effort / Earmarking § 200.303

ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342, Corrective Action Plan: Internal Controls and Compliance - Student Financial Assistance Returns - UM - The University of Montana - Missoula and the University of Montana - Western implemented their remediation plans from the prior audit...

ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342, Corrective Action Plan: Internal Controls and Compliance - Student Financial Assistance Returns - UM - The University of Montana - Missoula and the University of Montana - Western implemented their remediation plans from the prior audit. Additional controls have been implemented, including the creation of a template guide, documentation of each calculation, and an additional review, to ensure accurate calculations and timely return of unearned Title IV aid. Person(s) Responsible for Corrective Measures: Ginger Lowry, Financial Aid Director, University of Montana - Missoula Louise Driver, Financial Aid Director, University of Montana - Western, Target Date: Completed

View Audit 317490

Finding 481400 (2024-001)

Significant Deficiency 2023

Flathead Valley Community College

MT

Student Financial Aid Eligibility Significant Deficiency

Finding: 2024-01 Federal Agency Name: Department of Education Assistance Listing Number: 84.063 Program Name: Student Financial Aid Cluster - Pell Finding Summary: During testing of students that were disbursed Pell Grants, three students out of a total of 40 that were tested did not receive th...

Finding: 2024-01 Federal Agency Name: Department of Education Assistance Listing Number: 84.063 Program Name: Student Financial Aid Cluster - Pell Finding Summary: During testing of students that were disbursed Pell Grants, three students out of a total of 40 that were tested did not receive the appropriate amount of Pell Grant. Corrective Action: The Pell amounts were reviewed when the error was found during the audit. Students with incorrect amounts were then awarded additional funding based on Title IV guideline. Going forward the following steps will be taken to ensure the error does not occur in the future: • Financial aid staff will review the Financial Aid awarding system prior to awarding and make sure the correct fields have been updated to show the correct Pell cost of attendance. • A second review will be conducted again at census prior to disbursing funds • A final review will be conducted at the end of the semester.Responsible Individual: Crystal Morris, Director, Financial Aid Anticipated Completion Date: March 2024

View Audit 317429

Finding 481279 (2023-005)

Significant Deficiency 2023

Albion College

MI

Student Financial Aid Reporting Significant Deficiency

Condition: Changes in a student’s status are required to be reported to the NationalStudent Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34...

Condition: Changes in a student’s status are required to be reported to the NationalStudent Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Planned Corrective Action: The Registrar’s office in conjunction with the Financial Aid office will implement controls to ensure accurate and timely reporting to NSLDS for student enrollment status. The current cause of the untimely reporting is due to students missing social security numbers with our database which does not allow them to match to existing student in NSLDS. A report is being created through Argos (reporting software) that will be run on a monthly basis to be sure all students have the proper information needed for enrollment reporting. This report is being created through the registrar’s office and will work in conjunction with financial aid to get these records updated according with the accurate SS# for the students. Enrollment reporting is done through National Student Clearinghouse which returns error reports for a multitude of different reason one being SS#. The Assistant Registrar handles all enrollment reporting on a monthly basis. After each monthly submission the Registrar will be cross referencing the error reports to be sure that all necessary errors have been corrected and cleared. The Assistant Registrar will also be doing an analysis on the Argos report that pulls all data for the enrollment reporting submission to be sure that all data fields are still correct due to system changes on a consistent basis. Contact person responsible for corrective action: Drew Dunham, Registrar and Trevor Markovich, Financial Aid Director Anticipated Completion Date: August 1, 2024

View Audit 317350

Finding 481275 (2023-004)

Significant Deficiency 2023

Albion College

MI

Student Financial Aid Reporting § 200.502 § 200.510

Condition: The schedule of expenditures of federal awards (SEFA) was not complete and accurate. Planned Corrective Action: The Albion College Business Office has established revised procedures for SEFA funds, in tandem with the Financial Aid Office, in which all Federal Awards and Grants will be rec...

Condition: The schedule of expenditures of federal awards (SEFA) was not complete and accurate. Planned Corrective Action: The Albion College Business Office has established revised procedures for SEFA funds, in tandem with the Financial Aid Office, in which all Federal Awards and Grants will be reconciled on a quarterly basis, to be completed no later than the end of the first proceeding month of the quarter. The procedures create a dual-control process for the drawdown, recordation, and reporting of SEFA funds. Additionally, in FY24, the Perkins portfolio was divested. The Perkins Close-out will be part of the FY24 Single Audit. Contact person responsible for corrective action: W. Scott Roberts Anticipated Completion Date: 06/30/2024

View Audit 317350

Finding 480017 (2023-007)

Significant Deficiency 2023

Idaho State University

ID

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

2023-007: Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Ma...

2023-007: Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: ISU should implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the intuition and are reported timely. We also recommend that the University implement a formal review procedure to document the review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During our discussion, it became apparent that a significant portion of the findings pertaining to the Office of the Registrar stemmed from enrollment status change not being reported to NSLDS within 60 days. To remedy this, we have added three new automated enrollment uploads right after the upload of the graduation file respectively in Fall, Spring and Summer. The three automated enrollment uploads to be sent to NSLDS are scheduled as follows: 1. On February 16; 2. On June 3; 3. On September 1. Name(s) of the contact person(s) responsible for corrective action: Hala Abou Arraj, Registrar Planned completion date for corrective action plan: Implemented in February 2024

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