Corrective Action Plans

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Name of Responsible Individual: Ransom Prestridge, Registrar; Jennifer Wegman, Assistant Registrar; Kai Howard, Institutional Research; Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the findings related to the timeliness and accuracy of enrollment reporting to th...
Name of Responsible Individual: Ransom Prestridge, Registrar; Jennifer Wegman, Assistant Registrar; Kai Howard, Institutional Research; Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the findings related to the timeliness and accuracy of enrollment reporting to the National Student Loan Data System (NSLDS). The identified exceptions were the result of insufficient administrative oversight and internal controls related to enrollment status reporting at both the campus and program levels. As this is a repeat finding, the College is committed to implementing enhanced and sustainable corrective measures. To address this finding, the College will strengthen internal controls and oversight of enrollment reporting by implementing the following corrective actions: • Establish a documented review and monitoring process to ensure all enrollment status changes, including graduation, withdrawal, attendance level changes, and second majors, are accurately and timely reported to NSLDS at both the campus and program levels. • Implement a standardized tracking and reconciliation process between the Registrar’s Office, the Student Information System, and NSLDS to ensure data consistency and completeness. • Develop and implement written policies and procedures that clearly define roles, responsibilities, timelines, and escalation protocols for enrollment reporting. • Enhance oversight of any third-party servicer, including periodic validation of submitted records to ensure accuracy and timeliness. • Provide comprehensive training to staff responsible for enrollment reporting on federal regulatory requirements and institutional procedures. • Conduct periodic internal quality assurance reviews and monitoring of enrollment reporting to identify and correct discrepancies in a timely manner. • Establish formal communication protocols between the Financial Aid and Registrar’s Offices to ensure timely notification of all enrollment changes. Anticipated Completion Date: May 31, 2026
Name of Responsible Individual: Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the exceptions identified related to the timeliness of Return of Title IV (R2T4) calculations and the return of unearned federal funds. The errors were the result of insufficient admini...
Name of Responsible Individual: Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the exceptions identified related to the timeliness of Return of Title IV (R2T4) calculations and the return of unearned federal funds. The errors were the result of insufficient administrative oversight and internal controls over the withdrawal and R2T4 process. To address this finding, the College will strengthen internal controls and oversight to ensure compliance with federal regulations. The corrective actions include: • Implementing a documented secondary review process for all R2T4 calculations prior to finalization to ensure accuracy and compliance with regulatory requirements. • Enhancing procedures to ensure timely identification of withdrawn students and prompt initiation of the R2T4 calculation process. • Establishing standardized monitoring to ensure all required returns of Title IV funds are processed within the regulatory timeframe. • Developing and implementing a tracking system to monitor withdrawal dates, calculation completion, and return deadlines. • Providing additional training to Financial Aid staff on federal R2T4 regulations and institutional procedures. • Conducting periodic internal quality assurance reviews of R2T4 calculations and returned funds to ensure ongoing compliance. Anticipated Completion Date: May 31, 2026
Name of Responsible Individual: Larry Bomback, Interim CFO / DeMornai Blackwell, Controller Corrective Action: Management acknowledges the instances in which Title IV credit balances were not refunded within the required regulatory timeframe under 34 CFR §668.164(c). Although no questioned costs wer...
Name of Responsible Individual: Larry Bomback, Interim CFO / DeMornai Blackwell, Controller Corrective Action: Management acknowledges the instances in which Title IV credit balances were not refunded within the required regulatory timeframe under 34 CFR §668.164(c). Although no questioned costs were identified, the College recognizes the need to strengthen internal controls to ensure full compliance. To address this finding, the College will: • Implement a formal Title IV credit balance monitoring procedure requiring weekly review of student accounts with credit balances • Establish an automated report identifying all Title IV–generated credit balances and tracking the 14-day refund deadline • Strengthen coordination between the Business Office, Financial Aid Office, and Registrar to ensure enrollment status and disbursement timing are properly reflected prior to refund processing • Continued documented supervisory review of credit balance aging reports These corrective measures are designed to ensure timely refunds, improve monitoring controls, and maintain compliance with federal Title IV requirements. Anticipated Completion Date: May 31, 2026
Management acknowledges the deficiency in the preparation and oversight of the Schedule of Expenditures of Federal Awards (SEFA) for the year ended May 31, 2025. To address this finding, the College will: • Implement a formal SEFA preparation policy aligned with 2 CFR §200.510(b) • Develop and maint...
Management acknowledges the deficiency in the preparation and oversight of the Schedule of Expenditures of Federal Awards (SEFA) for the year ended May 31, 2025. To address this finding, the College will: • Implement a formal SEFA preparation policy aligned with 2 CFR §200.510(b) • Develop and maintain a centralized federal awards tracking log identifying: o Federal agency o Program name o Assistance Listing Number (ALN) o Award number o Pass-through entity (if applicable) o Expenditures by fiscal year • Establish quarterly reconciliations between the general ledger and the federal awards tracking log • Require structured cross-departmental communication between the Business Office, Financial Aid Office, Grants Administration, and program departments to ensure all federal awards received and expended are identified timely • Implement documented management review and approval of the SEFA prior to submission to auditors These corrective measures will strengthen internal controls over federal award tracking, improve the accuracy and completeness of the SEFA, and ensure compliance with Uniform Guidance requirements. Anticipated Completion Date: May 31, 2026
Name of Responsible Individual: Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the reporting errors identified in certain student origination records submitted to the Common Origination and Disbursement (COD) System, specifically related to cost of attendance and ...
Name of Responsible Individual: Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the reporting errors identified in certain student origination records submitted to the Common Origination and Disbursement (COD) System, specifically related to cost of attendance and academic end date data elements. To address this finding, the College will enhance internal controls and oversight over federal aid reporting by implementing the following corrective actions: • Establish a documented secondary review process for all origination records prior to submission to COD, with verification of key data elements including cost of attendance, academic start and end dates, enrollment status, and award amounts. • Implement a standardized review checklist to ensure accuracy and completeness of required data fields. • Strengthen reconciliation procedures between the student information system and COD to identify and resolve discrepancies timely. • Conduct periodic internal quality assurance reviews of origination and disbursement records. • Provide additional staff training on federal reporting requirements. Anticipated Completion Date: This process has already been implemented.
Name of Responsible Individual: Larry Bomback, Interim CFO ; Justin Roy, VP of Enrollment ; Irene Langran, VP of Academic Affairs Corrective Action: Management acknowledges the instance in which Title IV funds were held beyond the allowable timeframe under 34 CFR §668.166. Although the amount was wi...
Name of Responsible Individual: Larry Bomback, Interim CFO ; Justin Roy, VP of Enrollment ; Irene Langran, VP of Academic Affairs Corrective Action: Management acknowledges the instance in which Title IV funds were held beyond the allowable timeframe under 34 CFR §668.166. Although the amount was within allowable tolerance thresholds and no questioned costs were identified, the College recognizes the need to strengthen internal controls over cash management compliance. To address this finding, the College will: • Implement a formal Title IV drawdown and disbursement monitoring procedure requiring review no later than the third business day following receipt of funds • Establish a standardized reconciliation process between the Business Office, Financial Aid Office, and Registrar to ensure timely identification of: o Students who have withdrawn o Enrollment status changes o Required returns of Title IV (R2T4) calculations • Develop a documented weekly reconciliation of federal drawdowns to disbursements and student account activity • Assign clear responsibility for monitoring excess cash thresholds and ensuring timely return of funds to the U.S. Department of Education when required • Provide cross-functional training to reinforce compliance requirements under federal cash management regulations These measures are intended to ensure timely disbursement of Title IV funds, proper reconciliation of enrollment changes, and full compliance with federal cash management requirements. Anticipated Completion Date: May 31, 2026
2025-007: Medication assistance was provided to a patient who was not eligible to receive assistance on the date of service due to active insurance coverage for the prescription. The Organization’s eligibility procedures were not supported by a formal policy or consistently followed as written. Addi...
2025-007: Medication assistance was provided to a patient who was not eligible to receive assistance on the date of service due to active insurance coverage for the prescription. The Organization’s eligibility procedures were not supported by a formal policy or consistently followed as written. Additionally, the Procedure for Medication Financial Assistance provides Community Health Workers and other staff significant discretion in making eligibility determinations. This flexibility and subjective process, while intended to reduce barriers to patients obtaining opioid use disorder treatments, increases the risk for inconsistent and inappropriate eligibility determinations. Responsible Persons: Karen R. White, CPA, Chief Executive Officer and Matthew Derryberry, Chief Financial Officer Completion Date: May 2026 Views of responsible officials and planned corrective actions: Issues identified during the audit were indicative of an overall lack of controls and processes by grant directors and Finance Department staff. The Organization has reviewed the processes and has developed a formalized policy for medication assistance eligibility determinations, clearly identifying grant requirements for eligibility. Additionally, the procedure associated with the policy identifies the need for secondary review of eligibility determinations and clear communication to the Finance Department along with adequate record keeping. The Organization’s CEO, a former CFO of the organization, will continue to provide oversight for the Finance Department to ensure controls and processes are implemented.
2025-006: Procurement records were not maintained according to Uniform Guidance. The Organization did not comply with its procurement policy. Responsible Persons: Karen R. White, CPA, Chief Executive Officer and Matthew Derryberry, Chief Financial Officer Completion Date: May 2026 Views of responsib...
2025-006: Procurement records were not maintained according to Uniform Guidance. The Organization did not comply with its procurement policy. Responsible Persons: Karen R. White, CPA, Chief Executive Officer and Matthew Derryberry, Chief Financial Officer Completion Date: May 2026 Views of responsible officials and planned corrective actions: Issues identified during the audit were indicative of an overall lack of controls and processes due to the change in Finance Department staff and loss of knowledge. Based on the finding, a review and training for the Organization on procurement has been implemented. Additionally, with the new CFO and Finance staff, additional controls and processes to prevent this from occurring again. The Organization’s CEO, a former CFO of the organization, will continue to provide oversight for the Finance Department to ensure controls and processes are implemented.
2025-005: Funds available from program income were not disbursed before the Organization requested additional drawdowns. The Organization was not appropriately with tracking and utilizing program income. Responsible Persons: Karen R. White, CPA, Chief Executive Officer and Matthew Derryberry, Chief ...
2025-005: Funds available from program income were not disbursed before the Organization requested additional drawdowns. The Organization was not appropriately with tracking and utilizing program income. Responsible Persons: Karen R. White, CPA, Chief Executive Officer and Matthew Derryberry, Chief Financial Officer Completion Date: August 2025 Views of responsible officials and planned corrective actions: Issues identified during the audit were indicative of an overall lack of controls and processes due to the change in Finance department staff and loss of knowledge. As of August 2025, program income is no longer being generated by the grant. The new CFO and Finance staff have also implemented processes and controls to ensure proper tracking and utilization of program income related to grants. The CEO will provide ongoing oversight to ensure processes and controls are being adhered to by the Finance Department.
2025-004: On January 27, 2025, the Office of Management and Budget (OMB) ordered a pause to the disbursement of federal grants to take effect the following day. Due to uncertainty around how long the pause would last and the Organization’s anticipated cash flow needs, management advance drew on the ...
2025-004: On January 27, 2025, the Office of Management and Budget (OMB) ordered a pause to the disbursement of federal grants to take effect the following day. Due to uncertainty around how long the pause would last and the Organization’s anticipated cash flow needs, management advance drew on the Organization’s federal awards on January 28, 2025. Responsible Persons: Karen R. White, CPA, Chief Executive Officer and Matthew Derryberry, Chief Financial Officer Completion Date: May 2025 Views of responsible officials and planned corrective actions: This is a once in a lifetime occurrence based on uncertainty and the Organization’s cash position at the time. The Organization has reviewed the cash management policy to ensure it is compliant. Additionally, the Organization has taken steps to improve its cash position and do not view this as an ongoing issue.
2025-003 Salaries and wages are charged to federal awards through separate manual tracking worksheets for each award. Additionally, although salaries and wages are allocated to grants in the Organization’s accounting system, the allocation only occurs at a summary level, moving all costs from admini...
2025-003 Salaries and wages are charged to federal awards through separate manual tracking worksheets for each award. Additionally, although salaries and wages are allocated to grants in the Organization’s accounting system, the allocation only occurs at a summary level, moving all costs from administrative rather than where they were recorded. Responsible Persons: Karen R. White, CPA, Chief Executive Officer and Matthew Derryberry, Chief Financial Officer Completion Date: January 2026 Views of responsible officials and planned corrective actions: Issues identified during the audit were indicative of an overall lack of controls and processes to ensure no double dipping occurs. The new CFO along with the newer members of the Finance Department have developed better controls and processes to ensure grant expenditures, including payroll expenses and allocations, are properly accounted for in the accounting system with adequate backup of grant draw downs. With the implementation of a new payroll system and a new accounting system in 2026, these issues should resolve themselves with oversight provided by the CFO. The Organization’s CEO, a former CFO of the organization, will continue to provide oversight for the Finance Department to ensure controls and processes are implemented.
Management’s Response – Based on legal counsel’s advice, and that the lender has an approved Concept Meeting Proposal with HUD, we believe HUD has approved our efforts to pursue predevelopment activities to add 29 units on the existing parcel using available cash from operations, while seeking forma...
Management’s Response – Based on legal counsel’s advice, and that the lender has an approved Concept Meeting Proposal with HUD, we believe HUD has approved our efforts to pursue predevelopment activities to add 29 units on the existing parcel using available cash from operations, while seeking formal approval and ultimately loan proceeds from a HUD-insured supplemental loan under Section 241(a) of the National Housing Act. Once the new loan is approved, we intend to use a portion of the proceeds from the HUD-insured supplemental loan to repay the Project’s Operating Account for funds used to cover predevelopment costs.
2025-1: A checklist of required documentation should be used to review all tenant files to identify all missing documentation. Management should then make arrangements with the tenant to complete missing information. A review of all current tenant files should be completed annually.
2025-1: A checklist of required documentation should be used to review all tenant files to identify all missing documentation. Management should then make arrangements with the tenant to complete missing information. A review of all current tenant files should be completed annually.
2025-1: Management agrees with the finding; subsequent to year-end review of the tenant files will be conducted and missing documentation will be completed.
2025-1: Management agrees with the finding; subsequent to year-end review of the tenant files will be conducted and missing documentation will be completed.
Management’s Response: The University has undertaken several initiatives to enhance compliance and accuracy: Management acknowledges the material weakness related to the awarding and disbursement of TEACH Grants and recognizes the importance of ensuring that grant eligibility is verified in accordan...
Management’s Response: The University has undertaken several initiatives to enhance compliance and accuracy: Management acknowledges the material weakness related to the awarding and disbursement of TEACH Grants and recognizes the importance of ensuring that grant eligibility is verified in accordance with federal regulations prior to disbursement. During fiscal year 2025, an eligibility determination error was identified for one student. Subsequent to year-end, the University returned the related TEACH Grant funds to the U.S. Department of Education through the G5 system. Management has taken corrective actions to strengthen eligibility verification and prevent recurrence. Corrective actions implemented include: • Strengthened Leadership and Oversight: A new Financial Aid Director was hired in March 2025 and has prioritized the development and enforcement of appropriate controls over TEACH Grant awarding and disbursement. • Revised Policies and Procedures: TEACH Grant awarding and disbursement procedures were reviewed and updated to ensure alignment with federal eligibility requirements. • Improved Eligibility Documentation: The TEACH Grant application was enhanced to clearly document all required eligibility criteria and support consistent eligibility determinations. • Secondary Review Controls: A secondary review and approval process has been implemented to ensure that TEACH Grant eligibility is independently verified prior to awarding and disbursement. • Enhanced Tracking and Monitoring: Additional tracking mechanisms were implemented to confirm that eligibility requirements are met and documented before funds are applied to student accounts. • Ongoing Compliance Monitoring: The Financial Aid Office continues to monitor TEACH Grant activity to ensure continued compliance with program requirements. Management believes these actions have significantly strengthened internal controls over TEACH Grant awarding and disbursement. Continued application of these procedures is expected to prevent recurrence and support full compliance in future audit periods. These initiatives demonstrate the University’s commitment to maintaining accurate student enrollment records and ensuring compliance with federal regulations, thereby safeguarding the interests of its students and the institution.
Management’s Response: The University has undertaken several initiatives to enhance compliance and accuracy: Management acknowledges the material weakness related to enrollment reporting for the Federal Direct Student Loan Program and recognizes the importance of timely and accurate reporting to the...
Management’s Response: The University has undertaken several initiatives to enhance compliance and accuracy: Management acknowledges the material weakness related to enrollment reporting for the Federal Direct Student Loan Program and recognizes the importance of timely and accurate reporting to the National Student Loan Data System (NSLDS). During fiscal year 2025, the University experienced challenges related to enrollment reporting accuracy and timeliness. In response, management implemented significant corrective actions to strengthen accountability, improve cross-department coordination, and enhance monitoring controls. Key actions taken during and subsequent to fiscal year 2025 include: • Strengthened Leadership and Accountability: A new Financial Aid Director was hired in March 2025 and has prioritized the resolution of this repeat audit finding. Clear responsibility for enrollment reporting oversight has been established. • Improved Cross-Department Coordination: The Financial Aid Office now works closely with the Registrar’s Office and Information Technology to ensure alignment between institutional enrollment records and federal reporting systems. • System Configuration Review: Enrollment reporting processes and system configurations within the Colleague system were reviewed to ensure that student enrollment statuses and effective dates are captured and reported accurately. • Identification and Correction of Reporting Issues: Management identified discrepancies in enrollment reports generated by Colleague that resulted in inaccurate federal reporting for certain students. Corrective solutions have been identified and implemented to address these issues. Enhanced Monitoring and Review: The Financial Aid Director now performs regular reviews of all withdrawn and graduated students to verify consistency between Colleague, the National Student Clearinghouse, and NSLDS prior to and after submission. • Improved Timeliness of Corrections: Any discrepancies identified are promptly reviewed and corrected in coordination with the Registrar’s Office to ensure compliance with required reporting timeframes. • Policy and Training Enhancements: Policies and procedures related to enrollment reporting are being refined, and additional staff training has been implemented to reinforce compliance requirements and internal controls. Management believes these actions have materially improved the accuracy and timeliness of enrollment reporting. Continued monitoring and application of these controls are expected to result in sustained compliance and resolution of this finding in a future audit period. These initiatives demonstrate the University’s commitment to maintaining accurate student enrollment records and ensuring compliance with federal regulations, thereby safeguarding the interests of its students and the institution.
The University had one R2T4 finding that resulted from a unique situation. The Financial Aid Office will conduct a detailed review of the process and incorporate this specific circumstance into its internal audit procedures. By strengthening internal controls within the R2T4 process and enhancing in...
The University had one R2T4 finding that resulted from a unique situation. The Financial Aid Office will conduct a detailed review of the process and incorporate this specific circumstance into its internal audit procedures. By strengthening internal controls within the R2T4 process and enhancing internal audit protocols, the University will further improve overall compliance in this area and maintain its high standard of regulatory compliance.
The Financial Aid Office will continue to work closely with the Registrar's Office and Information Technology to resolve the NSLDS reporting discrepancies. Based on our preliminary review, the reporting inconsistencies appear to be related to changes in enrollment reporting processes and data feeds ...
The Financial Aid Office will continue to work closely with the Registrar's Office and Information Technology to resolve the NSLDS reporting discrepancies. Based on our preliminary review, the reporting inconsistencies appear to be related to changes in enrollment reporting processes and data feeds associated with the recent Student Information System (SIS) update, implemented in 2025. In partnership with the Registrar's Office, Information Technology, and the Office of Data Analytics (within Information Technology), the University will identify and correct the source of the repeated or inconsistent data submissions to the National Student Clearinghouse. Because enrollment reporting to the Clearinghouse directly impacts data reported to the National Student Loan Data System (NSLDS), resolving these data feed issues is a priority. Additionally, these departments will develop and implement enhanced internal controls to compare institutional enrollment records against NSLDS data to ensure accuracy and timeliness. One of these measures will include a monthly enrollment reporting audit to identify and correct discrepancies proactively. Updates may include but not be limited to timing and frequency of reporting, internal audits monthly during 2026, and expanding written documentation of the process and procedures. The University is committed to strengthening internal processes to ensure compliance with federal enrollment reporting requirements and to prevent recurrence of this issue.
While the District maintained the requisite supporting documentation, limitations arising from the internal record retention policies in place at the time, coupled with the retirement of key personnel, resulted in certain enrollment records not being readily locatable. The District acknowledges that...
While the District maintained the requisite supporting documentation, limitations arising from the internal record retention policies in place at the time, coupled with the retirement of key personnel, resulted in certain enrollment records not being readily locatable. The District acknowledges that these factors limited the availability of prior-year supporting data. This issue has since been addressed through updated retention practices to ensure that this does not occur going forward. Beginning with the next fiscal year cycle, the District has implemented a documented procedure that specifies the data sources, query parameters, and data pull dates; requires that all supporting extracts and calculations be retained in a centralized, version-controlled folder; and establishes a formal review and approval process to verify that enrollment and low-income counts reconcile to source documentation before submission to ADE. Staff in Federal Programs and Finance have been trained on the new procedure, and an annual internal review has been established to confirm compliance. The Director of Finance and the Director of Federal Programs are responsible for implementing and monitoring this corrective action, which will be completed prior to the next Title I eligibility submission.
Finding 2025-005 Program: SFA Cluster Assistance Listing No.: Various Federal Agency: Department of Education Award Year: FY 2024 – 2025 Compliance Requirement: Consistent with the requirements of 2 CFR Part 200, Subpart F, Part 3, the auditor is required to test internal controls related to major p...
Finding 2025-005 Program: SFA Cluster Assistance Listing No.: Various Federal Agency: Department of Education Award Year: FY 2024 – 2025 Compliance Requirement: Consistent with the requirements of 2 CFR Part 200, Subpart F, Part 3, the auditor is required to test internal controls related to major programs. The specific procedures to test internal control on a caseby-case basis considering factors such as the non-federal entity’s internal controls, the compliance requirements, the audit objectives for compliance, the auditor’s assessment of control risk, and the audit requirement to test internal controls. University’s Response: University management recognizes the finding and has addressed the issue. The Cost of Attendance calculation error affected a single student and resulted in an overaward of $400, which has been corrected and refunded to the Department of Education. Management believes the issue was isolated in nature and does not indicate a systemic weakness in the University’s awarding or billing processes. Corrective Action Plan The University reviewed the circumstances related to this finding and determined that the Cost of Attendance (COA) calculation error was limited in scope and affected a single student. The overaward of $400 has been corrected, and the required refund has been processed to the Department of Education. Management believes the condition was isolated in nature and does not indicate a systemic issue within the University’s awarding or billing processes. The University will continue to rely on its existing awarding and billing procedures, which are designed to support compliance with federal financial aid requirements. No additional corrective action is planned at this time. Existing procedures remain in effect. Name of the responsible person: Megan Inch, Associate Vice President of Student Financial Planning; Brad Calloway, Senior Vice President for Business Affairs Anticipated completion date: Resolved
Finding 2025-004 Program: SFA Cluster Assistance Listing No.: Various Federal Agency: Department of Education Award Year: FY 2024 – 2025 Compliance Requirement: Consistent with the requirements of 2 CFR Part 668, Subpart B, Part 16, the University is required to identify and resolve discrepancies in...
Finding 2025-004 Program: SFA Cluster Assistance Listing No.: Various Federal Agency: Department of Education Award Year: FY 2024 – 2025 Compliance Requirement: Consistent with the requirements of 2 CFR Part 668, Subpart B, Part 16, the University is required to identify and resolve discrepancies in the information received from different sources with respect to each student’s financial aid. University’s Response: The University identified that certain ISIR comment codes (including ISIR “C” flags) were not properly mapped within the student information system. As a result, those comment codes were not displayed or identified for review within the system workflow. At the time financial aid was disbursed, there were no unresolved C‑flags visible in the system requiring resolution prior to disbursement. The University self‑identified this system configuration issue and disclosed it to its auditors. Upon identification, the ISIR comment code mapping was corrected, and the University performed a review of affected records to ensure all required eligibility issues were identified and resolved. As a result of this issue, financial aid was disbursed to three students who were later determined to require additional eligibility review. The University refunded $160,789 to the Department of Education related to these students. Additionally, one student was determined to have been ineligible for aid in a prior award year, resulting in an additional refund obligation of $31,571, which remains payable to the Department of Education at the time of report issuance. Corrective Action Plan: The ISIR comment code mapping issue has been corrected, and all identified affected records have been reviewed and resolved. Management believes the condition resulted from a specific system configuration issue and was isolated in nature. No additional corrective action is planned at this time. The University believes the corrective actions already taken have addressed the root cause of the issue and that existing processes are operating as intended. Name of the responsible person: Megan Inch, Associate Vice President of Student Financial Planning; Brad Calloway, Senior Vice President for Business Affairs Anticipated completion date: Resolved
Finding 2025-003 Program: Grants to States for Medicaid Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Award Year: FY 2024 – 2025 Compliance Requirement: Consistent with the requirements of the subaward agreement, the University is required to submit comp...
Finding 2025-003 Program: Grants to States for Medicaid Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Award Year: FY 2024 – 2025 Compliance Requirement: Consistent with the requirements of the subaward agreement, the University is required to submit compliance reporting to the grantor annually beginning in the year the funds were received. University’s Response: The University was not provided with the required compliance reporting templates at the time the subaward was issued. As a result, the University was unable to submit the required reports during the applicable reporting period. The grantor did not request submission of the reports during this time. Upon becoming aware of the reporting requirement during the Single Audit process, the University requested the appropriate templates and reporting guidance from the grantor. The templates were subsequently provided, and the University is continuing to work with the grantor to ensure accurate completion and submission of the required compliance reporting. The University confirms that grant funds were used in accordance with the terms and allowable activities of the subaward agreement. Corrective Action Plan: The University will continue to seek clarification and guidance from the grantor regarding required compliance reporting and the appropriate format for submission. If sufficient guidance is not provided, the University will submit the required compliance reporting to the best of its ability based on available information, understanding that the submission may be subject to review or revision by the grantor. No additional corrective action is planned at this time. The University will continue to work with the grantor to address reporting requirements as information becomes available. Name of the responsible person: Brian Shollenberger, Vice President for Financial Affairs and University Development Anticipated completion date: May 31, 2026
Finding 2025-002 Program: Federal Work Study Assistance Listing No.: 84.033 Federal Agency: Department of Education Award Year: FY 2024 – 2025 Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify all amounts paid are appropriately earned. University’s Respon...
Finding 2025-002 Program: Federal Work Study Assistance Listing No.: 84.033 Federal Agency: Department of Education Award Year: FY 2024 – 2025 Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify all amounts paid are appropriately earned. University’s Response: The University uses Workday HCM as the official system of record for student employee time reporting. Student workers record time directly in Workday, and supervisors review and approve time entries each pay period prior to payroll processing. The time punches in question were reviewed and approved in Workday in accordance with standard procedures at the time of payment. Because the audit occurred six to eighteen months after the work was performed by the students, supervisors were unable to independently recall specific hours worked beyond the documentation maintained in Workday. However, system records indicate that the hours were reviewed and approved, and the University confirmed that any questioned amounts were offset by subsequent allowable hours worked. As noted by the auditors, questioned costs of $508 were identified; however, no return of Federal Work‑Study funds was required based on allowable offsetting hours. Corrective Action Plan: The University will continue to rely on its existing Federal Work‑Study timekeeping and payroll procedures, which require that student wages be based on hours worked in allowable positions. Management believes the condition identified was isolated in nature and not indicative of a systemic issue within the Federal Work‑Study program. No additional corrective action is planned at this time. Existing procedures remain in effect. Repeat Finding Explanation This finding is reported as a repeat due to similar conditions noted in the prior year related to Federal Work‑Study payroll documentation. However, the current‑year finding reflects a reduced scope, a lower number of students, and a significantly reduced questioned cost amount compared to the prior year. Management believes the issue is not systemic. Name of the responsible person: Marc Sears, Vice President of Human Resources; Brad Calloway, Senior Vice President for Business Affairs; Sandra Fantauzzi, Student Employment Program Manager; Megan Inch, Associate Vice President of Student Financial Planning
Finding 2025-001 Program: Federal Family Education Loans Assistance Listing No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely mann...
Finding 2025-001 Program: Federal Family Education Loans Assistance Listing No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled student’s account within 3 business days following the receipt of funds. University’s Response: The excess cash balance relates to prior award years and is not part of the currently audited period. The University has maintained these funds in a segregated federal funds account and safeguarded them from expenditure while performing reconciliation. The University is actively coordinating with the Department of Education to determine the appropriate process for returning the excess cash and will follow their guidance once received. The University has continued to ensure these funds are not comingled and has protected them from spending. Because of the discrepancies identified, each student’s loan history had to be reviewed and compared between the University Information System, the lender rosters, and the National Student Loan Database System (NSLDS) records. This individual review and reconciliation have proven to be a tedious but necessary process to identify the funds never posted to student records, returned to lenders, or entered incorrectly in the three separate systems of record. Corrective Action Plan: The University, working with an external financial aid consulting firm with experience in reconciling FFEL loan programs, has finished researching all related accounts against the National Student Loan Database System (NSLDS) records. The University continues to work with the Department of Education to determine how to return funds in instances where the last lender used is no longer available to process student loan funds, and lastly, book the appropriate entries for any funds determined to belong to the University that were not moved to the University operating accounts properly at the time of the transactions. Name of the responsible person: Brad Calloway, Senior Vice President for Business Affairs Anticipated completion date: Unknown
Finding 2025-008 – Allowable Costs/Cost Principles and Matching, Level of Effort, and Earmarking Contact Person: Susan Rios, Grants Manager Current status: In-Progress Anticipated Completion Date: February 06, 2026 Condition: The University did not have effective internal controls over the timely pr...
Finding 2025-008 – Allowable Costs/Cost Principles and Matching, Level of Effort, and Earmarking Contact Person: Susan Rios, Grants Manager Current status: In-Progress Anticipated Completion Date: February 06, 2026 Condition: The University did not have effective internal controls over the timely preparation and approval of employees’ time and effort certifications. Identification of repeat finding: N/A Resolution: The Time and Effort Reporting form was updated on February 6, 2026, to more accurately reflect the semesters covered by the form submitted by the respective program. The Grants Accounting Office will obtain the completed forms within 90 days of the last day of the performance period. The forms will be completed on a biannual basis and collected from each respective program within 90 days following the end date of the most recent semester.
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