Corrective Action Plans

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RE: Single Audit Finding 2023-001 I provide the following information regarding the Town of Lincoln’s Corrective Action Plan: Finding 2023-001 Condition: Obligations were overstated by $1,435,098 on March 31, 2023 Project and Expenditure report. Corrective Action Planned: The Town now has a cle...
RE: Single Audit Finding 2023-001 I provide the following information regarding the Town of Lincoln’s Corrective Action Plan: Finding 2023-001 Condition: Obligations were overstated by $1,435,098 on March 31, 2023 Project and Expenditure report. Corrective Action Planned: The Town now has a clear understanding of the reporting requirements for obligations, and will report the correct amounts in the next report. Anticipated Completion Date: March 31, 2024 Contact: Colleen Wilkins, Finance Director/Town Accountant, wilkinsc@lincolntown.org 781-259-2673 Please let me know if you have any questions or if you need additional information. Sincerely, Colleen Wilkins Finance Director/Town Accountant Town of Lincoln 16 Lincoln Rd. Lincoln, MA 01773
Finding 2023-001 – Procurement and Suspension and Debarment Federal Grantor: U.S. Department of Education Pass-through Grantor: Pennsylvania Department of Education Program: Early Intervention (Philadelphia), Early Intervention (Chester) Assistance Listing #: 84.027, 84.173 Title: Special Educatio...
Finding 2023-001 – Procurement and Suspension and Debarment Federal Grantor: U.S. Department of Education Pass-through Grantor: Pennsylvania Department of Education Program: Early Intervention (Philadelphia), Early Intervention (Chester) Assistance Listing #: 84.027, 84.173 Title: Special Education Cluster (IDEA) Audit Period: 07/01/2022 – 06/30/2023 Passthrough Numbers: 232-210026, 231-210026, 232-210035, 231-210035 Recommendation: We recommend Elwyn enforce its existing policy and procedures to ensure compliance with procurement requirements. Elwyn should provide targeted training to members of the organization involved in procurement processes on its existing policy and procedures to ensure understanding of the Organization’s requirements for documentation of procurement methods. Additionally, Elwyn should ensure all procurement decisions are contemporaneously documented with the information necessary to conclude on appropriateness of the procurement with respect to the procurement policy and requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The purchasing department will conduct an annual training with organizational leadership regarding the Elwyn’s procurement policy. This training will help to reinforce the existing procurement documentation requirements. In addition, the purchasing department will create and distribute a purchasing checklist and tracking form that will be utilized for new procurements and renewals. This form will help to ensure that the procurement method and rationale are appropriately documented and approved by organizational personnel. The completed form will be submitted to the purchasing department for electronic storage and retention. Name of contact person responsible for corrective action: David Bowers, Vice President of Finance and Corporate Controller Email: David.bowers@elwyn.org Phone: 610-891-2028 Planned completion date for corrective action plan: June 30, 2024
Recommendation: We recommend the Organization implement a documented review process for reimbursement requests before submitting the requests monthly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CommUnity has p...
Recommendation: We recommend the Organization implement a documented review process for reimbursement requests before submitting the requests monthly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CommUnity has put into place an added month end process that includes verification that all billing has been reviewed. Name(s) of the contact person(s) responsible for corrective action: Angie Meiers Planned completion date for corrective action plan: February 2024
Recommendation: We recommend the Organization documents review of all payroll reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CommUnity has put into place an added payroll process that includes monthly ver...
Recommendation: We recommend the Organization documents review of all payroll reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CommUnity has put into place an added payroll process that includes monthly verification that all reports have been reviewed. Name(s) of the contact person(s) responsible for corrective action: Angie Meiers Planned completion date for corrective action plan: February 2024
Unified School District #446 Independence, Kansas Corrective Action Plan January 17, 2024 Cognizant or Oversight Agency for Audit Unified School District #446 respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting...
Unified School District #446 Independence, Kansas Corrective Action Plan January 17, 2024 Cognizant or Oversight Agency for Audit Unified School District #446 respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Jarred, Gilmore & Phillips, PA, P.O. Box 779, 1815 S Santa Fe, Chanute, Kansas 66720. Audit period: Year ended June 30, 2023 The findings from the January 17, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding: 2023-001 – Verification Condition: During our testing of verification of income of households sampled during the year, we tested all households chosen for verification. During this testing, we noted households whose net income was used to calculate their eligibility instead of their gross income. Recommendation: Procedures should be implemented requiring that all income should be verified using proper documentation and verification results review by at least two or more qualified individuals. Action Taken: We are in agreement with the recommendation and the District has updated review procedures to ensure that free and reduced lunch verifications are reviewed by at least two people and that gross wages are used in the calculations. Anticipated Complete Date: November 8, 2023 Should the Oversight Agency for Audit have questions regarding this plan, please contact Gina Godinez, Director of Finance, at (620) 332-1800. Sincerely Unified School District #446 Unified School District #446
Management recognizes the compliance requirements of 2CFR200 and the additional compliance requirements of the funding source. The Chief Operating Officer and other grant-funded employees have received training and guidance on allowable costs, and we have adjusted the review process for grant report...
Management recognizes the compliance requirements of 2CFR200 and the additional compliance requirements of the funding source. The Chief Operating Officer and other grant-funded employees have received training and guidance on allowable costs, and we have adjusted the review process for grant reports to include detailed review of allowable costs by the Chief Operating Officer prior to submission to the grantor. The Chief Operating Officer is responsible for implementing the corrective action plan. Training for allowable cost was completed December 2023 for all grant funded employees. The detailed review by the Chief Operating Officer will occur with each bill submitted.
US Department of Education: Education Stabilization Fund - Assistance Listing 84.425F Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Explanation of disagreement with audit finding: There is no disagreement...
US Department of Education: Education Stabilization Fund - Assistance Listing 84.425F Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The University is already utilizing Visual Compliance to assess all vendors for suspension and debarment but will obtain and document the review of the SOC 2 report for Visual Compliance annually. Name(s) of the contact person(s) responsible for corrective action: Scott Schlotthauer, Chief Procurement Officer. Planned completion date for corrective action plan: Immediately.
US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.038, 84.063, 84.268, 84.379, 84.033 Recommendation: CLA recommends that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disag...
US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.038, 84.063, 84.268, 84.379, 84.033 Recommendation: CLA recommends that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: OSU is creating a GLBA management program to govern security of GLBA data and ensure compliance with associated requirements. Name(s) of the contact person(s) responsible for corrective action: Aaron Smith, Director of Information Security Services/Information Security Officer. Planned completion date for corrective action plan: March 31, 2024
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.
US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063, 84.268, 84.033 Recommendation: CLA recommends OSU CHS and OSUIT evaluate its procedures around disbursements of loans and ensure documentation is properly retained. Explanation of disagreement ...
US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063, 84.268, 84.033 Recommendation: CLA recommends OSU CHS and OSUIT evaluate its procedures around disbursements of loans and ensure documentation is properly retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: OSU CHS: Financial aid staff have added a process to Banner to automatically generate a notification e-mail to students when loans are disbursed. OSUIT: The query that OSUIT runs to send emails to the students and reports the results to OSUIT Financial Aid staff has been changed from reporting one term at a time to report disbursements from any term as long as the change in a prior term happens within the last 24 hours. In addition, staff will be retrained on how to review the reports and the reports will now go to all Financial Aid staff so that multiple staff may review reports. Name(s) of the contact person(s) responsible for corrective action: OSU CHS: Jeff Hackler, Associate Dean for Enrollment Management. OSUIT: Matt Short, Director of Financial Aid and Scholarships. Planned completion date for corrective action plan: OSU CHS: Already implemented. OSUIT: December 1, 2023.
Finding 369086 (2023-003)
Significant Deficiency 2023
Management will look to stregthen this control during the next fiscal year by evaluating employee's job responsibilities and having one employee be in charge of federal grants.
Management will look to stregthen this control during the next fiscal year by evaluating employee's job responsibilities and having one employee be in charge of federal grants.
Finding 369085 (2023-001)
Significant Deficiency 2023
The Board of Directors and SAFE on Main Management team have adopted a formal procurement policy effective January 2024. This policy gives guidance for procurements over $10,000 and other purchasing policies of the Organization. Darrico Murray, Executive Director, oversees these policies on behalf...
The Board of Directors and SAFE on Main Management team have adopted a formal procurement policy effective January 2024. This policy gives guidance for procurements over $10,000 and other purchasing policies of the Organization. Darrico Murray, Executive Director, oversees these policies on behalf of the Organization
The status of real property purchased, constructed, or subject to major renovations paid for in whole or in part with federal Head Start funds must be reported annually on standard forms (SF) Real Property Status Reports 429 and SF-429-A. Based on our grant agreement for our Early Head Start Program...
The status of real property purchased, constructed, or subject to major renovations paid for in whole or in part with federal Head Start funds must be reported annually on standard forms (SF) Real Property Status Reports 429 and SF-429-A. Based on our grant agreement for our Early Head Start Program in Washington, DC , as well as construction activities undertaken throughout Fiscal Year 2023 related to the facility located at 1151 Bladensburg Road, NE, Easter Seals DC | MD | VA is required to file the aforementioned forms no later than 90 days after the program year ends. As noted in the audit report, our organization did not file the required SF-429 Form for the latest program year (FY 2023) for our Washington DC EHS program. The director for the Head Start program was aware of the Real Property Status filing requirement, but apparently misunderstood that the deadline for the Year 2 (FY 2023) filing was September 30, 2023. We anticipate that the required reports will be submitted to the appropriate governing agency by March 31, 2024.
Based on our grant agreement with Head Start, Easter Seals DC | MD | VA is required to provide a 20% contribution of total project costs for each annual budget period, unless a waiver has been requested and approved; any combination of actual cash expended, or in-kind contributions, may be used to m...
Based on our grant agreement with Head Start, Easter Seals DC | MD | VA is required to provide a 20% contribution of total project costs for each annual budget period, unless a waiver has been requested and approved; any combination of actual cash expended, or in-kind contributions, may be used to meet the matching requirement. Our organization met the 20% non-federal match requirement for the latest program year (Year 2) for our Early Head Start Program in Washington DC. However, we did not meet the match requirement for Year 5 of our Prince George County program. The mandatory annual waivers associated with our organization’s 20% non-federal share matching contribution requirement for the first four years (2019 - 2022) of the individual award periods ended July 31 of our Prince George’s County Head Start Program grant agreement have been submitted. Likewise, the waiver request for the first year (2022) of the individual award period ended June 30, 2022, for our Washington, DC Head Start Program grant agreement has also been submitted. Per Section 640(b)(1)(5) of the Head Start Act, a waiver request for Year 5 (2023) was submitted alongside the original budget narrative. While the budget was approved, we were notified after the program year ended that a standalone/separate waiver request for Year 5 was required. The outstanding waiver requests remain under review by representatives of The Administration of Families and Children, the agency that oversees the Office of Head Start program. We have maintained a constant dialogue with the Office of Head Start, which administers grant funding and oversight, but have yet to receive formal approval for any of the outstanding waiver submissions. However, we believe that amended waiver requests will be required for some of the program years in which we did not meet our 20% non-federal contribution match in Prince George’s County. In December 2023, we provided the Office of Head Start with additional details related to the organization’s annual expenditures, cash receipts, and non-federal share obligations for the first five years of the Prince George’s County grants. We anticipate that final responses to all five required waiver requests our Prince George’s County Program will be obtained no later than the end of the current grant year (July 31, 2024). We expect the outstanding waiver request for Year 1 of our Washington DC program will be considered and approved by the end of the current grant year (July 31, 2024).
FINDING 2022 – 009: Repeat of Prior Year Finding 2021-012 Type of Finding: Allowable Costs and Activities Name of Responsible Individual: Gregory Bloomfield (304-243-2233) Criteria: Reporting: The American Rescue Plan (ARP) established two new required uses of HEERF III institutional portion grant f...
FINDING 2022 – 009: Repeat of Prior Year Finding 2021-012 Type of Finding: Allowable Costs and Activities Name of Responsible Individual: Gregory Bloomfield (304-243-2233) Criteria: Reporting: The American Rescue Plan (ARP) established two new required uses of HEERF III institutional portion grant funds for public and private nonprofit institutions in which a portion of funds must be used to: (a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances. Condition: The University did not use any portion of the HEERF III institutional funds to conduct direct outreach to financial aid applicants. Corrective Action: The University will formalize and document financial processes to establish internal controls in order to ensure accurate, timely and consistent reporting. In addition, this will create a reasonable transition plan during employee turnover, as well as ensure proper and timely filings. Anticipated Completion Date: Correction Action complete as this Federal program has been since exhausted; no further disbursements nor reporting requirements to date.
FINDING 2022 – 008: Type of Finding: Cash Management Name of Responsible Individual: C.F.O., Gregory Bloomfield (304-243-2233) Criteria: Reporting: The University is required to disburse student aid payments within 15 calendar days after the draw down of the fund. Condition: For 4 out of 35 students...
FINDING 2022 – 008: Type of Finding: Cash Management Name of Responsible Individual: C.F.O., Gregory Bloomfield (304-243-2233) Criteria: Reporting: The University is required to disburse student aid payments within 15 calendar days after the draw down of the fund. Condition: For 4 out of 35 students selected for testing the funds were disbursed to the students more than 15 days after funds were drawn down. Corrective Action: The University will formalize and document financial processes to establish internal controls in order to ensure accurate, timely and consistent reporting. In addition, this will create a reasonable transition plan during employee turnover, as well as ensure proper and timely filings. Anticipated Completion Date: Correction Action complete as this Federal program has been since exhausted; no further disbursements nor reporting requirements to date.
FINDING 2022 – 007 Repeat of Prior Year Finding 2021-011 Type of Finding: Significant Deficiency - Reporting Federal Award Program: COVID – 19 Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and COVID – 19 HEERF Institutional Portion Federal Agency: U.S. Department of Education As...
FINDING 2022 – 007 Repeat of Prior Year Finding 2021-011 Type of Finding: Significant Deficiency - Reporting Federal Award Program: COVID – 19 Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and COVID – 19 HEERF Institutional Portion Federal Agency: U.S. Department of Education Assistance Listing Number: 84.425E, 84.425F Federal Award Year: June 30, 2022 Name of responsible Individual: C.F.O., Gregory Bloomfield Criteria: Reporting: The University was required to submit to the Department of Education an annual report of its HEERF expenditures using the Annual Report Data Collection System by May 6, 2022. Additionally, the institution is required to post accurate and completed quarterly HEERF information to its primary website. Condition: The annual report was not completed or submitted. Additionally, certain amounts reported on submitted quarterly reports did not reconcile to underlying supporting documentation. Corrective Action: The University will formalize and document financial processes to establish internal controls in order to ensure accurate, timely and consistent reporting. In addition, this will create a reasonable transition plan during employee turnover, as well as ensure proper and timely filings. Anticipated Completion Date: Full implementation and documentation with current staffing is currently in process and estimate completion by March 31, 2024, however, HEERF has since ended so no further reporting is necessary.
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.
2023-001 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063 Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Explanation of disagreement with...
2023-001 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063 Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Explanation of disagreement with audit finding: As a standard, regular practice, communicates disbursement information for Federal Pell and Federal loans to COD no less than once per week; therefore, we believe we have an adequate way to report disbursements to COD within 15 days of the disbursement date. MACC transitioned to new financial aid processing software (Jenzabar Financial Aid - JFA) in summer 2022 while other areas of the college were still using the "old" system (Jenzabar CX). We experienced a glitch during the transition in which the files did not update as expected, we worked with our software vendor to correct the issue. Below is the timeline of action taken:This finding pertains to one student with Sub and Unsub Loans. We posted aid and sent the original batch on Friday, 07/15/2022; we discovered the issue on Wednesday, 07/20/2022, and reached out to Jenzabar immediately; we followed up with Jenzabar on Thursday, 07/28/2022 because the records were not updated; the records were updated on Monday, August 1. Action taken in response to finding: MACC continues to submit disbursement information at least once per week and review student details for posting accuracy. We took the necessary steps to fix the issue. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: We believe this finding was an anomaly due to the system conversion. We have no evidence of this happening since.
2023-003 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accuratel...
2023-003 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College 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, but we offer the following explanation: Identification of Errors and Corrections to New SIS: • Conversion to a new SIS (Jenzabar - Jl) was effective November 2022, and forced subsequent Fall 2022 NSC Enrollment Transmittal Files to be created in the new system mid-term. The concern of enrollment report timing was brought to the vendor multiple times before the transition. However, due to scheduling limitations on the vendor's end, the transition to the new system had to be completed mid-term. • In late May/early June we began end of term processing and reconciliations, and we identified that student status changes were not properly pulling the correct enrollment status information through the vendor's enrollment report creation process. • Support tickets were sent to the vendor immediately to address the problems with the system process that creates NSC Transmittal Files. • System configuration changes were made as recommended by the vendor to properly update enrollment status changes. • Through the investigation of these configuration changes, additional system errors were identified that were not allowing some enrolled students to be properly pulled to the enrollment files. • Support engagements continued with the vendor throughout July and August to identify and correct the system configuration to correctly pull enrolled students into the NSC Transmittal File. This was completed by the end of summer term, and the final summer enrollment file contained the correct number of students enrolled with the correct final enrollment status. • Internal validation reports were created and executed to ensure that correct student data was transmitted on the Fall first of Term reports. We believe this transmission contained the correct number of students and the correct status. These internal validation reports will be conducted prior to all NSC submissions. Creation of new/additional reports will be conducted as necessary. • We have been able to verify that the Fall 2023 subsequent term enrollment file did contain accurate status change information, and this issue is now resolved. • By correcting status change configurations, we have also identified that program begin dates converted from the old SIS to the new SIS were incorrectly mapped. • We are currently in the process of identifying the ID#s with incorrect program begin dates and making manual updates to the students' record in the new SIS environment. The vendor has not provided a clear path to programmatically correct this in bulk, so this record validation is being completed one-by-one manually. We project to have this completed for currently enrolled students by the final fall 2023 enrollment submission. Correcting previously submitted data: • We reached out to our Data Analyst, Elizabeth Fennessy, with the National Student Clearinghouse, to begin working on a corrective action for the missing status change data. • Elizabeth consulted with the NSC Audit Resource Team, and the following plan was recommended to MACC: • For students Less Than Half Time Spring 2023 or Withdrawn Spring 2023 that re-enrolled Summer 2023, these would be a manual update in NSLDS for Title IV students in these scenarios using NSLDS site 'Enrollment History Update.' • Later in Clearinghouse, the same update can be reflected using Clearinghouse site 'Student Look-Up' to bring the record current with updated enrollment reflected Spring 2023. By updating NSLDS first, that will avoid an NSLDS error "certification date out of sync" (error code 32). • MACC prepared reports to retrieve students meeting the criteria identified above. • These students' enrollment statuses for Spring 2023 and Summer 2023 have been manually updated in NSLDS Enrollment History Update and in NSC Student Look-up to bring these enrollment statuses up to date; this has been a long and time-consuming process. • We are also currently working on reports to identify students that were enrolled in spring 2023 but missed when the NSC Enrollment Transmittal File was created. We believe that students missed in Summer 2023 have been brought up to date through the submission of the corrected final Summer 2023 Enrollment File (to include students that were also enrolled in Spring 2023). Any student that was inadvertently excluded from the Spring 2023 and has not been brought up to date through subsequent corrected submissions, will be manually corrected through NSC Student Look-Up, and NSLDS Enrollment History Update if necessary. • We also reached out to l<athy Feith, Branch Chief, l<C School Participation Division, Federal Student Aid, U.S. Department of Education; she is aware of our issues. She recommended making enrollment changes directly in NSLDS for students who withdrew. Action taken in response to finding: The following is our Corrective Action Plan. • The Registrar will review data in J1 and submit enrollment records to NSC each month. o The Registrar will also work with the Director of Administrative Computing to ensure program information and other vital data are reported correctly. o MACC will continue to work with Jenzabar for a solution for reporting last dates of attendance for students who are withdrawn from all classes. • After the enrollment file is accepted by NSC, 20 randomly selected students will be verified for accuracy. • The selection will be made by the Director of FA and/or Registrar. • The selection will include students who have withdrawn from all classes and had an R2T4 calculation performed. • The Registrar, or designee, will review the data in NSC. • The Associate Director of Financial Aid, or designee, will review the data in NSLDS. • Discrepancies will be addressed between the Registrar and Financial Aid Offices immediately; and will utilize the Director of Administrative Computing to assist with configuration changes and data clean-up. • The records will be maintained in a designated Teams folder. Name(s) of the contact person(s) responsible for corrective action: Amy Hager and Amy See (Registrar). Planned completion date for corrective action plan: We expect the plan will be an ongoing effort to ensure compliance.
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