Finding Number: 2025-003 Condition: The University did not have controls in place to ensure appropriate reporting to COD. Planned Corrective Action: The primary cause of this issue was the significant lack of training and support provided during the implementation of Anthology Student. Similar to th...
Finding Number: 2025-003 Condition: The University did not have controls in place to ensure appropriate reporting to COD. Planned Corrective Action: The primary cause of this issue was the significant lack of training and support provided during the implementation of Anthology Student. Similar to the challenges experienced with Return to Title IV (R2T4) processing, University staff did not receive adequate instruction on how to perform Title IV reconciliations within the system or how to extract the data needed to compare internal records with COD. This lack of foundational training made it extremely difficult for staff to understand required reconciliation procedures, identify discrepancies, or troubleshoot system-related issues. In addition, the technical limitations of Anthology Student significantly hindered the University’s ability to perform timely and accurate reconciliations. Anthology Student does not provide a comprehensive or efficient reporting tool that allows users to pull Title IV awarding and disbursement data in a format that aligns with COD records. Staff must manually compile information from multiple system screens and reports, a process that takes several hours and still does not produce a clean, fully reconcilable output. Discussions with other Anthology client institutions confirmed that they are experiencing similar challenges with timely reconciliations due to the system’s reporting limitations. Compounding these reporting challenges, the batch transmission functionality between Anthology Student and COD has been unreliable. Files routinely fail or become “stuck” during transmission, but Anthology offers limited visibility into batch processing status. Until February 2026, the University relied on a system report to identify failed or stalled batches; however, an Anthology system update removed this report and the capability altogether. Without access to this tool, staff have had little ability to monitor or verify successful COD transmission, further complicating reconciliation efforts. Another contributing factor is staffing capacity. The Financial Aid Office has limited personnel, and the extensive time required to manually pull data, consolidate reports, and investigate discrepancies has made it challenging to dedicate the uninterrupted hours required for reconciliation—especially without adequate system training or tools. The University is taking the following steps to address this finding: 1. Scheduled Reconciliation Intervals: Calendar reminders and dedicated appointment blocks will be established every 30–60 days to ensure staff have protected time to complete Title IV reconciliations. 2. Staff Training and Support: The Financial Aid Office will continue working with Anthology Support to obtain the training necessary to understand where and how to locate all required Title IV data within the system. We will also pursue additional training and documentation from Ellucian/Anthology on proper reconciliation procedures. 3. Enhanced Manual Oversight: Until system reliability improves, staff will continue performing manual reviews of Title IV disbursements, adjustments, and COD submissions to confirm accuracy and identify unresolved transmission issues. These actions will remain in place until Anthology Student provides reliable reporting capabilities and complete, consistent training, enabling the University to perform reconciliations accurately and on time. Contact person responsible for corrective action: Chad Curley, Director of Financial Aid Anticipated Completion Date: Scheduled reconciliation intervals were implemented beginning with the Spring 2026 semester on February 19, 2026. Staff training and the pursuit of additional system support will continue on an ongoing basis as part of the University’s continuous improvement efforts.