Corrective Action Plans

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Student Financial Assistance Cluster – Assistance Listing No. Various 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 ...
Student Financial Assistance Cluster – Assistance Listing No. Various 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: We have created a Stale check policy & procedure. The financial aid department will work in concert with student accounts and accounts payable to ensure compliance. The process has checkpoints starting at 30, 60 up to 180 days. 60 days before a check reaches 240 days. Name(s) of the contact person(s) responsible for corrective action: Lisa Stone, Joyce Hatch, Kelly Reyes, Michael Warner, Christy Krahn and Vikki Straw. Planned completion date for corrective action plan: November 2023
View Audit 290967 Questioned Costs: $1
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disa...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: After an analysis of the auditor's finding, ACU's director of financial aid, AVP of institutional effectiveness, and associate director of institutional research concluded that a misunderstanding of the National Clearinghouse's process for summer enrollment reporting was the cause of the finding. During the summer months of June, July, and August, ACU has been submitting enrollment reports, including withdrawals, only for students enrolled in summer terms. Withdrawals of students enrolled in the spring term were not being reported until after the fall term commenced. To remedy this finding, the Department of Financial Aid (FA) and the Office of Institutional Effectiveness (OIE) has coordinated with the National Student Clearinghouse (NSC) to identify which reporting method would ensure that all withdrawn students are accounted for and reported between the spring and fall terms. It was determined we would send custom files that include all withdrawn students in early June and July. The report will be uploaded through the NSC's secure file upload system at least once between May 30th and August 30th, with no more than 60 days between any two enrollment file submissions. Name(s) of the contact person(s) responsible for corrective action: Lisa Stone, Jeff Phillips and Eric Tompkins Planned completion date for corrective action plan: May/June 2024
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit fi...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The incorrect date was for a student who received the Pell Grant. When we batch Pell student awards in COD; and return funds at the same time, this will often cause a shortage in our Pell G5 account. This will delay the disbursement date on the school side. Although COD releases the disbursement, the funds are not available in G5 until days later and in some cases weeks later. The first step is to not process returns and draw downs at the same time. This will ensure the funds are in the Pell G5 acount so disbursment dates will match. The second piece is to audit the disbursement dates at the end of each semester to ensure we match. Name(s) of the contact person(s) responsible for corrective action: Lisa Stone, Joyce Hatch and Kelly Reyes Planned completion date for corrective action plan: November 2023
Finding 369499 (2023-001)
Significant Deficiency 2023
Wells College (the College) respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Bonadio & Co., LLP 432 North Franklin Street #60 Syracuse, New York 13204 Audit period: July 1, 2022 - June 30, 2023 The fin...
Wells College (the College) respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Bonadio & Co., LLP 432 North Franklin Street #60 Syracuse, New York 13204 Audit period: July 1, 2022 - June 30, 2023 The findings from the 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAMS AUDIT Finding 2023-001 - Student Financial Assistance Cluster Compliance Requirement N. Gramm-Leach-Bliley Act-Student Information Security Recommendation: Our auditors recommend that we conduct a formal risk assessment and update our written information security program (WISP) to ensure the seven required elements are addressed. As part of this process, Information Technology (IT) policies should be updated to align with our current IT environment and be formally approved and implemented throughout the College. Action Taken: Wells College is partnering with Grey Castle Security to do a Risk Assessment and Penetration test. This will be completed in February. Additionally, Grey Castle has helped to redraft our Incident Response Plan. This has been completed, and training on this plan is scheduled for later in January, with Tabletop simulations occurring with the Wells College Emergency Planning Team and IT in February. Over the next couple of months, IT will be refreshing its policies in collaboration with the Wells College Technology Advisory Group (TAG), a committee representing all areas of the college. Once TAG has approved policies, they will go to the Cabinet for approval. Multiple policies will be merged to create the WISP as a self-contained document, rather than the multiple policies in place. The Chief Financial Officer, Robert Cree, is responsible for implementing this plan by June 30, 2024, and can be reached at (315) 364-3408 or rcree@wells.edu .
Finding 369472 (2023-002)
Significant Deficiency 2023
Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: We agree with this recommendation. We continue strengthening the tracking system around the timely processing of R2T4 refunds. From the Fall 2023 semester, we developed a report within our Student Information System (SIS) to trac...
Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: We agree with this recommendation. We continue strengthening the tracking system around the timely processing of R2T4 refunds. From the Fall 2023 semester, we developed a report within our Student Information System (SIS) to track students who both received a loan and have dropped classes within Western Seminary’s SIS. From the Spring 2024 semester, we require attendance to be tracked in all classes, including in-person classes. We historically already track attendance of online courses. Financial Aid and the Business Office will have access to regularly scheduled reports to quickly identify when students stop attending class to determine whether an R2T4 form is required and should be processed. Person Responsible for Corrective Action Plan: Jonathan Gibson, CFO Anticipated Date of Completion: June 30, 2024
View Audit 290692 Questioned Costs: $1
Lack of Documentation of Exit Counseling Planned Corrective Action: Exit counseling letters have been emailed within 30 days of a student’s separation from Newberry College. A record of this notification is maintained in the financial aid software system for audit purposes. The senior associate...
Lack of Documentation of Exit Counseling Planned Corrective Action: Exit counseling letters have been emailed within 30 days of a student’s separation from Newberry College. A record of this notification is maintained in the financial aid software system for audit purposes. The senior associate director will be responsible for completing this process and the director will assist or complete, if necessary. Person Responsible for Corrective Action Plan: Karen Benfield, Director of Financial Aid Anticipated Date of Completion: This process is being implemented for the 2023-24 academic year.
Enrollment Reporting to NSLDS Planned Corrective Action: We have created a process with specific individuals responsible for updating and submitting the roster timely; train staff and create and follow policies and procedures to ensure no delays in reporting a change in status. We have designated...
Enrollment Reporting to NSLDS Planned Corrective Action: We have created a process with specific individuals responsible for updating and submitting the roster timely; train staff and create and follow policies and procedures to ensure no delays in reporting a change in status. We have designated an individual to pull a statistical report from NSLDS to verify the reporting is updated for each period of enrollment. Person Responsible for Corrective Action Plan: Marilyn Eason, Registrar Anticipated Date of Completion: This problem should be resolved when Newberry moves to the J1 platform this spring. It is expected enrollment reporting will be automated by the summer of 2024.
Monthly Reconciliations of Pell Grant and Federal Direct Loans Planned Corrective Action: Monthly reconciliations for the Pell Grant and Federal Direct Loan Programs have been completed to date for the 23-24 academic year. The senior associate director is responsible for completing monthly reconc...
Monthly Reconciliations of Pell Grant and Federal Direct Loans Planned Corrective Action: Monthly reconciliations for the Pell Grant and Federal Direct Loan Programs have been completed to date for the 23-24 academic year. The senior associate director is responsible for completing monthly reconciliations and the director will perform if necessary. Person Responsible for Corrective Action Plan: Karen Benfield, Director of Financial Aid Anticipated Date of Completion: This process is being implemented for the 2023-24 academic year.
Incorrect Pell Calculations Planned Corrective Action: The process for awarding and disbursing summer Pell Grants is being discussed. The new process will involve a thorough review of summer enrollment. Aid will disburse for session 1 and session 2 after the last day to add or drop a course. The ...
Incorrect Pell Calculations Planned Corrective Action: The process for awarding and disbursing summer Pell Grants is being discussed. The new process will involve a thorough review of summer enrollment. Aid will disburse for session 1 and session 2 after the last day to add or drop a course. The director will oversee summer awarding and the senior associate director will assist by providing necessary reports. Person Responsible for Corrective Action Plan: Karen Benfield, Director of Financial Aid Anticipated Date of Completion: This process will be finalized by June 2024.
View Audit 290607 Questioned Costs: $1
Gramm Leach Bliley Act (GLBA) Compliance Planned Corrective Action: The college has implemented policies and procedures to address GLBA compliance and is taking steps to address all exceptions noted. Person Responsible for Corrective Action Plan: Jon Kokos, CFO Anticipated Date of Completion...
Gramm Leach Bliley Act (GLBA) Compliance Planned Corrective Action: The college has implemented policies and procedures to address GLBA compliance and is taking steps to address all exceptions noted. Person Responsible for Corrective Action Plan: Jon Kokos, CFO Anticipated Date of Completion: June 30, 2024
Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The director is performing the R2T4 calculation, returning funds (if necessary), adjusting the student’s awards and bill in the appropriate software. The senior associate director is reviewing each student to be certain the cor...
Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The director is performing the R2T4 calculation, returning funds (if necessary), adjusting the student’s awards and bill in the appropriate software. The senior associate director is reviewing each student to be certain the correct funds are being reduced and/ or returned based on the calculation. Person Responsible for Corrective Action Plan: Karen Benfield, Director of Financial Aid Anticipated Date of Completion: This process is being implemented for the 2023-24 academic year.
Federal Supplemental Educational Opportunity Grant - Assistance List 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 Recommendation: We recommend the Universi...
Federal Supplemental Educational Opportunity Grant - Assistance List 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 Recommendation: We recommend the University document review of Return to Title IV calculations by an employee that did not prepare the calculations. We also recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and disbursed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial aid personnel will implement Return to Title IV FSA calculation spreadsheet for additional backup support in determining if banner has calculated return amounts correctly. Additionally, financial aid will require all R2T4 calculations to be secondarily reviewed and confirmed in RHACOMM. The scheduled breaks for each semester will be determined by the Director of Financial Aid and given to the Registrar to be input into banner module SOATBRK. These breaks are what banner then uses for Return to Title IV purposes. Update procedures to reflect additional actions. Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: 4/1/24
View Audit 290586 Questioned Costs: $1
Federal Supplemental Educational Opportunity Grant - Assistance List 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 Recommendation: We recommend the Univers...
Federal Supplemental Educational Opportunity Grant - Assistance List 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 Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the University disburse the proper Pell award to these students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Check Pell Calculation settings in banner and adjust, if needed, to achieve maximum accuracy based on student criteria (COA, EFC/SAI, Enrollment Status). Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: 4/1/24
Federal Supplemental Educational Opportunity Grant - Assistance List 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 Recommendation: We recommend the Universi...
Federal Supplemental Educational Opportunity Grant - Assistance List 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 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Ellucian, the producer of Banner, had a known defect that caused incorrect status change dates to be inserted in the Banner program which processes student enrollments. This defect was not known to me at the time, therefore, it was not something I was aware to be looking for when completing enrollment reporting. There were no errors which would have alerted me to the issue. See case PB006205. Known defect now seems to be corrected. Will review current processes in order to ensure the continuance of timely and accurate reporting, and to eliminate the possibility of future errors being at the fault of the University. Name(s) of the contact person(s) responsible for corrective action: Erin Moore and Dasha Smith Planned completion date for corrective action plan: 4/1/24
Federal Supplemental Educational Opportunity Grant - Assistance List 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 Recommendation: We recommend the Universi...
Federal Supplemental Educational Opportunity Grant - Assistance List 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 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Request a formal count of all graduates from Registrar at the end of each semester and review the number of exit counseling notifications sent from financial aid to ensure notifications are sent to all appropriate graduating students. Update procedures to reflect additional review. Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: 4/1/24
Rules set up within the system to generate a list of students who disbursed Title IV funds during each term failed when new academic year field was not updated for the new year. The Student Financial Planning Office identified the error on October 6, 2022 – six days over the 15 – day reporting requ...
Rules set up within the system to generate a list of students who disbursed Title IV funds during each term failed when new academic year field was not updated for the new year. The Student Financial Planning Office identified the error on October 6, 2022 – six days over the 15 – day reporting requirement. Error was identified and updated the system by creating new rule criteria. Management has updated the opening of a new federal year standard operating procedure (SOP). The updated SOP now has the running of the registered student credits process for the opening of each new academic year added to the annual calendar. In addition, management enhanced the eligibility rule criteria from one rule to two rules. By separating out the loan origination and acceptance rule into two separate rules an extra barrier of prevention has been added to help ensure only loans originated and accepted are disbursed to the student’s account. The College has complied since October 6, 2022, and no further findings were found after that date. Responsible Party: Jeanine Gemmell, Director of Student Financial Planning Completion Date: October 6, 2022
Detailed Reconciliations Between Common Origination and Disbursement (COD) and University Records Planned Corrective Action: The University understands and concurs with the auditors finding to the lack of a detailed reconciliation between the Common Origination and Disbursement (COD) and Univers...
Detailed Reconciliations Between Common Origination and Disbursement (COD) and University Records Planned Corrective Action: The University understands and concurs with the auditors finding to the lack of a detailed reconciliation between the Common Origination and Disbursement (COD) and University Records. While Cleary was reconciling monthly totals between the COD and University Records; it was brought to our attention during the audit that it needed to be in greater detail. Going forward, the plan of action will be that on a monthly basis; reports will be generated from the COD (Loan and Pell Disbursement Detail Reports) and compared to the Student Information System (SIS). This will be completed monthly on a student-by-student detailed basis. This will be completed by the Financial Aid Department with the assistance of the Business Office to ensure that accuracy. A copy of the monthly reconciliation will be saved in our Month End Folder; for Leadership to review at any time. Person Responsible for Corrective Action Plan: Michael Mathis, Director of Financial Aid Anticipated Date of Completion: January 2024
Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Planned Corrective Action: The University understands and concurs with the incorrect and untimely return of some Title IV funds. In response, the University has taken three (3) immediate steps to address this deficiency in the futu...
Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Planned Corrective Action: The University understands and concurs with the incorrect and untimely return of some Title IV funds. In response, the University has taken three (3) immediate steps to address this deficiency in the future. First, the institution has added financial aid staff with significant expertise and experience in the administration of the R2T4 process to periodically review standard and modular students R2T4 to ensure accurate, timely and compliant returns and reporting. Second, the University has identified policy and procedure improvements that align with best practice approaches to R2T4 administration in support of Pell recalculations and accurate return of funds. Finally, the institution has identified professional development opportunities for all financial aid, and associated personnel, to improve theoretical and practical awareness and implementation of the return process i.e., conference/webinar participation, in-house training workshops and discussions, identified liaison/unit champion roles, etc. Person Responsible for Corrective Action Plan: Michael Mathis, Director of Financial Aid Anticipated Date of Completion: January 2024
View Audit 290552 Questioned Costs: $1
US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063, 84.268, 84.033 Recommendation: CLA recommends OSU OKC and OSUIT review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately...
US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063, 84.268, 84.033 Recommendation: CLA recommends OSU OKC and OSUIT review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: OSU OKC: The Director of Financial Aid, Registrar, and Sr Director of Institutional Effectiveness developed a new process on reporting first of term, end of term, updates to enrollment, and processing errors in a timely manner. In addition, the Director of Financial Aid also added a step to the current OSU OKC R2T4 process. Financial Aid counselors will also be checking NSLDS on all students who populate on our R2T4 listing. Monthly, the Director of Financial Aid will select a small population to R2T4 and audit the information reported in NSLDS to ensure the new process is working correctly. OSUIT: OSUIT will shorten the dates for reporting to the NSLC to make sure the NSLC has sufficient time to report to NSLDS. Name(s) of the contact person(s) responsible for corrective action: OSU OKC: Elizabeth Lucas, Director of Financial Aid and Scholarships; Hank Lankford, Registrar; and Nick Irby, Senior Director of Institutional Effectiveness and Accreditation. OSUIT: Matt Short, Director of Financial Aid and Scholarships; and Crystal Palacioz, Registrar. Planned completion date for corrective action plan: OSU OKC: The completion date for the enrollment reporting has been implemented since the end of September 2023. The additional financial aid processes were implemented in October 2023 and will be fully completed by December 1, 2023. OSUIT: December 1, 2023.
FINDING 2022 – 004: Name of Responsible Individual: Tracy Jenkins, Student Accounts Type of Finding: Authorization for Retaining Credit Balance Criteria: Title IV regulations (34 CFR 668.165(b)) states that an institution must obtain written authorization from a student or parent in order to hold an...
FINDING 2022 – 004: Name of Responsible Individual: Tracy Jenkins, Student Accounts Type of Finding: Authorization for Retaining Credit Balance Criteria: Title IV regulations (34 CFR 668.165(b)) states that an institution must obtain written authorization from a student or parent in order to hold any Title IV program funds that would otherwise be paid directly to the student or parent as a credit balance. Condition: During testing auditors noted one student had a credit balance that was held beyond the end of the loan period without authorization from the student or parent to hold the funds. Corrective Action: During the testing, the audit report noted one student who had a credit balance that was held beyond the end of the loan period without authorization from the student or parent to hold the funds. In response to this finding, 2022-004 Wheeling University Student Accounts Office has added competent staff. Student Accounts has a set calendar for refund dates to coincide with each semester. The first refund distribution happens during the second week of classes for the semester. The exact process is followed for weeks three and four of the semesters. Week seven of the semester is the fourth distribution of refunds, and week nine is the fifth distribution of refund checks. The refund process is completed within seven days of disbursement notification. Anticipated Completion Date: This process was completed in August of 2023 and is an ongoing process.
FINDING 2022 – 003: Repeat of Prior Year Finding 2021-008 Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Type of Finding: Overaward of Title IV Funds Criteria: Title IV regulations (34 CFR 685.203) states in no case may Direct Subsidized, Direct Unsubsidized...
FINDING 2022 – 003: Repeat of Prior Year Finding 2021-008 Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Type of Finding: Overaward of Title IV Funds Criteria: Title IV regulations (34 CFR 685.203) states in no case may Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loans were intended, less (1) the student’s estimated financial assistance for that period and (2) the borrower’s expected family contribution for that period. Condition: During testing the auditors noted two instances where the University awarded a Direct Unsubsidized loan to a student that caused the student’s financial assistance received to be greater than the student’s cost of attendance. Corrective Action: At the time of these findings, all Wheeling University Financial Aid processing operations were being conducted manually. The high level of complexity commonly associated with financial aid processing creates an environment, especially when conducted in a manual format, that is error-intrinsic. Packaging and awarding for each of the federal student aid programs are currently conducted by using the student information system, Colleague, which allows the FA office to perform these processing operations in a fully automated manner. Proper use of the “auto-packaging” feature provides significant assurance that student awards will not exceed financial need based on Cost of Attendance (COA) and Estimated Family Contribution (EFC). Previous audit findings have noted a general lack of accuracy, organization, and documentation regarding the final figure for the COA, which can result in packaging and over-award errors. As such, the Acting Director of Financial Aid has completely extensively researched and input data into the system with an accurate, fair, and equitable formula for arriving at a COA while meeting student need and, consequently, reducing or eliminating the potential for over-awards. This data was obtained from state and local cost of living figures, input from other similar state schools, and by use of the higher education organization, the College Board. This data is available as a reference for future documentation and review in a shared electronic file. Anticipated Completion Date: This process was completed in March of 2023 and is ongoing.
View Audit 290469 Questioned Costs: $1
FINDING 2022 – 002: Repeat of Prior Year Finding 2021-004 Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Type of Finding: Federal Award Findings and Questioned Costs Criteria: Recipients of federal awards are required to administer its federal programs with ...
FINDING 2022 – 002: Repeat of Prior Year Finding 2021-004 Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Type of Finding: Federal Award Findings and Questioned Costs Criteria: Recipients of federal awards are required to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. Condition: The University did not reconcile its SAS data file to its financial records for all 12 months of the fiscal year. Corrective Action: Wheeling University has implemented several significant corrective actions towards improving the reconciliation requirements for the Pell and Direct Loan Programs. A highly administratively capable staff person has been promoted to Assistant Director and demonstrates a level of financial aid leadership that is appreciated throughout the campus community. This individual has received extensive regulatory and technical training regarding the federal requirements to monthly reconcile cash received from the G5 account with disbursements submitted to the COD System. In addition to confirming the accuracy of monthly reconciliation efforts, this approach allows the FA office to compare internal awarding databases against COD’s database for Pell and Direct Loan awards and identify discrepancies that require further attention. Also, this assists the University to be better prepared to perform efficient and accurate closeout activities at year-end. Previous audit findings showed little evidence of accurate reconciliation efforts. In working with the University IT Department, monthly reconciliation files are now housed in a shared electronic file system, easily retrieved for review, and are confirmed for accuracy by the acting Director of Financial Aide each month. Anticipated Completion Date: This process was completed in March of 2023 and is ongoing.
FINDING 2022 – 006: Type of Finding: Significant Deficiency-Return of Title IV Funds Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the...
FINDING 2022 – 006: Type of Finding: Significant Deficiency-Return of Title IV Funds Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the student based the calculated percent completed by the student. Condition: Calculations of return of funds for certain students selected for testing were not completed and therefore refunds were not made. Corrective Action: Audit results identify several Wheeling University Financial Aid R2T4 calculations that were found to be incomplete, inaccurate, or not completed within an acceptable time frame as required by regulations. The apparent cause of these findings was a lack of administrative capability, staff turnover, and a general lack of a systematic process for completing accurate R2T4 calculations. Since these findings were first noted, the Wheeling University Financial Aid Office has added competent staff and has provided sufficient training and supervised experience to ensure R2T4 calculations are completed within the regulatory guidelines. The acting Director of Financial Aid has taken steps to ensure to inform the campus community of the Department’s philosophy of an “institutional responsibility” regarding regulatory compliance with Title IV programs, and this is particularly true in the matter of student FA eligibility with enrollment, attendance, and withdrawal. As such, the acting Director of Financial Aid has worked closely with the University Registrar to ensure there is a clear understanding that if a recipient of Title IV grant or loan funds withdraws from the University after beginning attendance, the FA Office must perform an R2T4 calculation to determine the amount of Title IV assistance earned by the student. Since withdrawal information is critical to R2T4 calculations, a Withdrawal Report has been developed to better capture withdrawal data. This report is updated and reviewed by the FA Director (three times per week) to confirm the accuracy of such data. In addition, all R2T4 calculations are completed on the University's internal software (Colleague) rather than DOE software and follow an updated, more clearly defined R2T4 policy. Anticipated Completion Date: This process was completed September of 2023 and is ongoing.
FINDING 2022 – 005: Repeat of Prior Year Finding 2021-003 Type of Finding: Material Weakness-Enrollment Reporting Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Criteria: An institution is required to update students’ changes in status on the National Studen...
FINDING 2022 – 005: Repeat of Prior Year Finding 2021-003 Type of Finding: Material Weakness-Enrollment Reporting Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Criteria: An institution is required to update students’ changes in status on the National Student Loans Data System (NSLDS) website within 30 days of the date the institution becomes aware of the change in enrollment status for students that graduate, withdraw, or have an increase or decrease in attendance during the fiscal year (34 CFR 685.309). Condition: For certain students selected for testing who graduated or withdrew during the year, the University did not submit an appropriate and/or timely status change notification to the NSLDS website. A group of graduated students were erroneously reported as ‘withdrawn’ from the University. Corrective Action: Audit results identify several Wheeling University Enrollment Reports that were found to be incomplete, inaccurate, or not completed within an acceptable time frame as required by regulations. In response to finding 2022-005, Wheeling University has implemented several significant corrective actions towards improving Enrollment Reporting. The apparent cause of these findings was a lack of administrative capability, staff turnover, and a general lack of a systematic process for completing accurate Enrollment Reports to the National Student Clearing House (NSC) and National Student Loan Data System (NSLDS). Since these findings were first noted, the Wheeling University Registration Office and Financial Aid Office have added competent staff and have provided sufficient training and experience to ensure Enrollment Reports are completed within the regulatory guidelines. The Vice President of Enrollment has worked closely with the Financial Aid Office and the Registration Office to ensure there is a clear understanding of who reports to the National Student Clearing House and who is responsible for monitoring NSLDS. There are also weekly meetings between the Business Office, Registration, and Financial Aid to ensure all reporting is correct and completed in a timely manner. Anticipated Completion Date: A new process has been in place Since October 2023 and is ongoing.
2023-002 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. Explanation of disa...
2023-002 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. Explanation of disagreement with audit finding: MACC is an attendance taking institution and our regular practice requires review of attendance records two to three times per week. When the Financial Aid Office discovers students have withdrawn from classes, we review and calculate an R2T4 when required - usually within 1-5 days from the date it is discovered. This finding of a "late return" is due to a faculty member dropping a student outside of the dates required by our attendance policy. I would like to note that the R2T4 was performed timely and accurately as soon as the drop was identified. Action taken in response to finding: The issue was reported to the President, Vice Presidents, and Deans; as a result, the faculty were addressed and reminded of the importance to comply with the college's attendance policy. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: Our Vice President for Instruction will provide reminders of our policy with our faculty each semester. In the event that a faculty member does not comply with the attendance policy, their Dean will take disciplinary action.
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