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Finding 2025-007 – Procurement and Suspension and Debarment Contact Person: Michael R. Castilleja, Director of Procurement and Other Support Services Current status: Resolved Anticipated Completion Date: Completed May 31, 2025 Condition: The University did not have evidence that the University perfo...
Finding 2025-007 – Procurement and Suspension and Debarment Contact Person: Michael R. Castilleja, Director of Procurement and Other Support Services Current status: Resolved Anticipated Completion Date: Completed May 31, 2025 Condition: The University did not have evidence that the University performed suspension and debarment checks for contractors on SAM.gov prior to entering into the contracts. Identification of repeat finding: Yes – 2024-005 Resolution: As of the completion date, language was incorporated into all contract and purchase order templates requiring vendors to acknowledge that they are not suspended or debarred. The Grants Accounting Office will verify and document, prior to approving any expenditure exceeding $25,000, that the vendor is not listed as suspended or debarred in SAM.gov.
Finding 2025-006 – Procurement and Suspension and Debarment Contact Person: Michael R. Castilleja, Director of Procurement and Other Support Services Current status: In-Progress Anticipated Completion Date: March 1, 2026 Condition: The University did not maintain records for procurements sufficient ...
Finding 2025-006 – Procurement and Suspension and Debarment Contact Person: Michael R. Castilleja, Director of Procurement and Other Support Services Current status: In-Progress Anticipated Completion Date: March 1, 2026 Condition: The University did not maintain records for procurements sufficient to detail the history of the procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Identification of repeat finding: Yes – 2024-004; 2023-004 Resolution: UIW is committed to complying with 2 CFR 200.303 which requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The University will document the methodology used to select sole source or preferred vendor procurements through completion of the Sole Source/Preferred Vendor Justification Form. This documentation must include a clear and detailed rationale for vendor selection, an explanation of why competitive procurement was not feasible or appropriate, and a summary of any meetings, evaluations, market research, or review processes conducted prior to the final selection. A standardized Sole Source Justification Form is currently in place and will continue to be used in accordance with University policy. For procurements exceeding the micro-purchase threshold, completion and approval of the Sole Source/Preferred Vendor Justification Form is required prior to purchase. The required approval levels are based on procurement dollar thresholds. These approval levels will align with applicable federal, state, and institutional compliance requirements as listed in the University policy. All Sole Source/Preferred Vendor requests should be reviewed/signed by the requestor, Dean/Director and the Director of Procurement. The Grants Office and Procurement Office are responsible for reviewing and verifying all required documentation prior to purchase approval to ensure compliance with funding requirements and applicable regulations. The UIW Procurement Department conducts quarterly training sessions for the campus community. These sessions will include reinforcement of requirements and expectations related to sole source and preferred vendor procurement to promote consistent compliance and proper documentation practices.
Finding 2025-005 – Cash Management Contact Person: Cristen Alicea, Office of Financial Assistance Current status: Resolved Anticipated Completion Date: February 1, 2026 Condition: The University did not provide evidence that the School Account Statements (SAS) from ED were used to reconcile to the U...
Finding 2025-005 – Cash Management Contact Person: Cristen Alicea, Office of Financial Assistance Current status: Resolved Anticipated Completion Date: February 1, 2026 Condition: The University did not provide evidence that the School Account Statements (SAS) from ED were used to reconcile to the University’s financial and business records on a monthly basis during the year ended May 31, 2025. Identification of repeat finding: N/A Resolution: We maintain that we did reconcile to the School Account Statements, as evidenced by the reports that have been run against the SAS statements through the Banner job RLRDLRC. However, we did not maintain the individual monthly evidence of the mismatches identified on those reports, and their resolution. We are maintaining this evidence going forward.
Finding 2025-004 – Special Tests and Provisions – Disbursements to or on Behalf of Students Contact Person: Cristen Alicea, Office of Financial Assistance Ann Margaret Cervantes, Director of Business Office Current status: Resolved Anticipated Completion Date: Completed May 23, 2025 Condition: The U...
Finding 2025-004 – Special Tests and Provisions – Disbursements to or on Behalf of Students Contact Person: Cristen Alicea, Office of Financial Assistance Ann Margaret Cervantes, Director of Business Office Current status: Resolved Anticipated Completion Date: Completed May 23, 2025 Condition: The University was unable to provide evidence that internal controls over the return of credit balances to students were performed. Additionally, student credit balances were not identified and refunded to students within 14 days after the credit balance occurred. Identification of repeat finding: N/A Resolution: Our Outlook email folders have a limit on storage, despite using non-server folders to extend storage space and length of time. During 2024-2025, these folders reached full capacity and we were unable to send or receive any emails. We were instructed to delete older emails to regain functionality, which unfortunately meant that some of the automated emails that we use for our audit processes had to be deleted. Our Information Technology department was able to provide an online archive folder for Outlook emails that does not fill up, get deleted, or cause us to run out of space. Therefore, all emails proving processing will be available for review during next year’s audit. Please note that this control was in place, and was followed, but we are unable to provide the actual email output. In addition to the automated credit balance reports from ARGOS, the Business Office runs internal reports twice weekly to identify and process any pending credit balances.
Finding 2025-003 – Special Tests and Provisions – Disbursements to or on Behalf of Students Contact Person: Cristen Alicea, Office of Financial Assistance Current status: Resolved Anticipated Completion Date: Completed May 23, 2025 Condition: The University was unable to provide evidence that intern...
Finding 2025-003 – Special Tests and Provisions – Disbursements to or on Behalf of Students Contact Person: Cristen Alicea, Office of Financial Assistance Current status: Resolved Anticipated Completion Date: Completed May 23, 2025 Condition: The University was unable to provide evidence that internal controls were performed in relation to notifications of disbursements, including notification of the amount and type of Title IV funds students are expected to receive, and how and when those disbursements will be made (award letter), and when direct loans are being credited to a student’s account (direct loan notification). Identification of repeat finding: N/A Resolution: Our Outlook email folders have a limit on storage, despite using non-server folders to extend storage space and length of time. During 2024-2025, these folders reached full capacity and we were unable to send or receive any emails. We were instructed to delete older emails to regain functionality, which unfortunately meant that some of the automated emails that we use for our audit processes had to be deleted. Our Information Technology department was able to provide an online archive folder for Outlook emails that does not fill up, get deleted, or cause us to run out of space. Therefore, all emails proving processing will be available for review during next year’s audit. Please note that this control was in place, and was followed, but we are unable to provide the actual email output. There were no instances of non-compliance identified during this audit.
Finding 2025-002 – Special Tests and Provisions – Return of Title IV Funds Contact Person: Cristen Alicea, Office of Financial Assistance Current status: In-Progress Anticipated Completion Date: May 1, 2026 Condition: The University did not provide evidence of an effective review process to ensure t...
Finding 2025-002 – Special Tests and Provisions – Return of Title IV Funds Contact Person: Cristen Alicea, Office of Financial Assistance Current status: In-Progress Anticipated Completion Date: May 1, 2026 Condition: The University did not provide evidence of an effective review process to ensure the timely calculation and return of Title IV funds to ED. The University did not accurately calculate and return Title IV funds in a timely manner to ED, within 45 days after the date the institution determined that a student withdrew. Identification of repeat finding: Yes – 2024-002, 2023-002 Resolution: The Director of Financial Assistance performed a full review of all withdrawals during 2023-2024, and 2024-2025, to ensure calculations were complete, accurate, and funds returned as required. Documentation will be maintained for review by the auditors and the Department of Education to prove funds were returned correctly, even if not timely. The continuation of this issue was caused by the continued difficulty with recruiting and keeping financial assistance advisors, and the extraordinary disruption caused by the 2024-2025 FAFSA changes. We were unable to fully remediate our staffing issues during the 2024-2025 academic year. We brought on new staff which required extensive training. However, we are now able to spend more time focusing on compliance areas and will be able to fully implement our planned compliance controls during the 2025-2026 aid year. We will not have any returns unprocessed or made outside of 45 days after May 1, 2026. In addition to new staff and training, we will implement a secondary review process for all Return of Title IV transactions whereby an advisor will process the initial calculation and return, and then either the Assistant Director or Director of Financial Assistance will perform a secondary review which evaluates the date of the withdrawal, the date of determination, the eligible disbursed/non-disbursed aid amounts, the returned amounts, and confirms the returned amounts in Banner and COD. This internal review process will be performed upon 100% of Return of Title IV calculations each academic year.
Finding 2025-001 – Special Tests and Provisions – Enrollment Reporting Contact Person: Marisol M. Scheer, Registrar’s Office Cristen Alicea, Office of Financial Assistance Current status: In-progress Anticipated Completion Date: May 31, 2026 Condition: The University did not provide evidence of an e...
Finding 2025-001 – Special Tests and Provisions – Enrollment Reporting Contact Person: Marisol M. Scheer, Registrar’s Office Cristen Alicea, Office of Financial Assistance Current status: In-progress Anticipated Completion Date: May 31, 2026 Condition: The University did not provide evidence of an effective review process to ensure accurate and timely reporting of student status changes to NSLDS. The University did not report program enrollment effective date or student status to the NSLDS for 1 of 60 students selected for testing. Identification of Repeat Finding: Yes – 2024-001, 2023-001, 2022-001, 2021-001, 2020-001, 2019-002 Resolution: We would again like to reiterate that even though this is considered a repeat finding for enrollment reporting, this particular issue is different than the previous findings. The Registrar's Office has implemented a control whereby a sample of students are reviewed after submission to the National Student Clearinghouse. This student did not appear as part of the sample and was unknown until the audit. We have reviewed all pertinent files for this student and can confirm that all student processing had no errors. In an improvement effort, the Registrar's Office will provide a sample to the Office of Financial Assistance to review for successful data processing. The Registrar's Office has begun researching why the student was not reported but have been able to confirm no procedural errors or delays with the student record that could have caused reporting issues.
Audit Firm: Sikich Audit Period: For the Year Ended May 31, 2025 Criteria: An institution must use the Return to Title IV refund calculation (34 CFR 668.22) A. Comments on Findings and Recommendations Finding 2025-001 Incorrect R2T4 Refund Calculation Condition: Sikich tested twelve drop students an...
Audit Firm: Sikich Audit Period: For the Year Ended May 31, 2025 Criteria: An institution must use the Return to Title IV refund calculation (34 CFR 668.22) A. Comments on Findings and Recommendations Finding 2025-001 Incorrect R2T4 Refund Calculation Condition: Sikich tested twelve drop students and found six incorrect refund calculations. The condition was caused by not including proper break days from the students' Return to Title IV calculations. B. Actions Taken or Planned Finding 2025-001 Incorrect R2T4 Refund Calculation The R2T4 calculation process has been updated to transition into using the built-in R2T4 calculator in the Jenzabar Financial aid software system. This is to ensure that the scheduled break periods are accounted for when calculating the percentage of payment period completed. We have since discountinued using the COD R2T4 calculator. Financial aid staff have been retrained to proper R2T4 procedures including the correct treatment of institutional break days. A secondary review process has been put in place to ensure accuracy of R2T4 calculations prior to submission and processing. Judson University has credited the appropriate amounts to all affected students to resolve the discrepancies identified in this finding. Sarah Taylor Vice President for Business Affairs
Action To Be Taken: To ensure federal compliance for the Corona virus Relief Fund (ALN 21.019), the organization will implement a secondary review process. After the Executive Director prepares the federal financial reports, a designated member of the Board Finance Committee will review the supporti...
Action To Be Taken: To ensure federal compliance for the Corona virus Relief Fund (ALN 21.019), the organization will implement a secondary review process. After the Executive Director prepares the federal financial reports, a designated member of the Board Finance Committee will review the supporting documentation (General Ledger and invoices) for accuracy before the report is submitted to the granting agency.•Responsible Party: Executive Director and Board Finance Committee. Anticipated Completion Date: February 28, 2026.
Finding 2025-001 Recommendation: It is recommended that management work closely with the NSC and the DoE to ensure that student statuses are reported timely. View of Responsible Officials and Planned Corrective Actions: The late receipt of the ECAR was out of the University’s control due to a known ...
Finding 2025-001 Recommendation: It is recommended that management work closely with the NSC and the DoE to ensure that student statuses are reported timely. View of Responsible Officials and Planned Corrective Actions: The late receipt of the ECAR was out of the University’s control due to a known issue with the new system implemented by the DoE for the EApp (Eligibility Application), which created a delay in the updated branch code for Lancaster. Individual Responsible for Corrective Action: Deanna Daly, ddaly@sju.edu and Sarah Taylor, swilli01@sju.edu Anticipated Completion Date for Corrective Action: N/A – no further corrective action is needed from the University at this time.
Saint Mary’s University of Minnesota Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-003 - Cash Management Condition G5 Drawdown requests were not documented as reviewed and approved by a responsible party separate from the preparer. For 2 of the 7 G5 draws tested, there was no d...
Saint Mary’s University of Minnesota Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-003 - Cash Management Condition G5 Drawdown requests were not documented as reviewed and approved by a responsible party separate from the preparer. For 2 of the 7 G5 draws tested, there was no documentation of review or approval by someone other than the preparer. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: A form will be created to support each G5 draw or refund. Requestor will fill out the form, providing details of the transaction. The form will be reviewed and signed off by the Controller or EVP of Finance. The person performing the transaction in G5 will sign, attached all the appropriate back-up and file in a designated area for future reference. Name(s) of Contact Person(s) Responsible for Corrective Action: Karen Stellpflug, Controller and David Ansell, Assistant Vice President for Finance Anticipated Completion Date: March 31, 2026
Saint Mary's University of Minnesota Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-001 Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Addit...
Saint Mary's University of Minnesota Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-001 Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Additionally, The U.S. Department of Education (ED) requires that an institution must ensure that its administrative procedures for the FSA programs include an adequate system of internal controls or checks and balances to ensure compliance with FSA laws and regulations including the return of Title IV funds. Condition/Context: The federal aid refunds for 1 out of 8 of the students tested was not calculated correctly and subsequently, not returned within 45 days from the withdrawal date. The sample was not statistically valid. Also, the auditor noted that the University did not have evidence or documentation available to support the control/review process for return of Title IV calculations. Cause: The University's review procedures for the return of Title IV funds were not followed and the system was not programmed to ensure the correct withdrawal date was used in the calculation of the return of Title IV funds. Effect: The University was in possession of funds belonging to the federal government longer than allowed and could have incorrect return of Title IV calculations and return incorrect amounts to students and/or the ED. Questioned Costs: Not applicable. Recommendation: The University should adhere to its procedures for refunding awards and implement a more formal documented review process/control to ensure refunds are calculated correctly and timely and any returns are made within the required timeframe. Management Response: The University agrees with this finding. The JFA R2T4 calculation incorrectly populated the wrong date used to perform the calculation, thus causing the error. The error was corrected and the director performs the R2T4 and is working to have a back-up employee trained. Staffing levels will have to be brought up to allow for new financial aid staff to complete this task. Corrective Action Plan Corrective Action Planned: To ensure accuracy, the withdrawal date generated in the JFA calculation will be cross-referenced against the J1 SIS record. Once verified, this date will be documented alongside the R2T4 calculation. This process guarantees that the student's period of attendance is calculated using the correct data. Name(s) of Contact Person(s) Responsible for Corrective Action: Holly Weberg, Director of Financial Aid and new hire designee. Anticipated Completion Date: The director is still fulfilling the R2T4 duties until a new hire candidate is hired and trained.
Saint Mary's University of Minnesota Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-002 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and re...
Saint Mary's University of Minnesota Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-002 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: The change in student status for 8 of 26 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. The student status for 1 of 26 students tested was reported as a withdrawal although the student was on a leave of absence. In addition, for 7 of 26 students tested, the University was unable to provide sufficient support for the status change. The sample was not statistically valid. Cause: The University’s procedures for reporting all students was not designed appropriately in order to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned Costs: Not applicable. Recommendation: The University should revise its procedures to ensure accurate enrollment information is sent to the NSLDS within the required timeframe. Management Response: The University agrees with this finding. The University has been actively taking measures with the new student information system, Jenzabar, and procedures have been standardized across the University. An audit will be preformed to discover the inefficiencies. Corrective Action Plan Corrective Action Planned: The Registrar Office will submit the names of students to the Audit Resource team at NSC so they can research why these students were not reported to NSLDS. As a result of their response, we will meet with the financial aid team to determine the next course of action to audit files. Any changes needed for NSC reporting will be implemented in May 2026 new submission. The University will also work with the system provider to rectify these discrepancies systematically to avoid further conflicts. Name(s) of Contact Person(s) Responsible for Corrective Action: Alison Block, Director of Academic Records and Systems and Holly Weberg, Director of Financial Aid. Anticipated Completion Date: Tentative completion date May 2026.
Finding 2025-002: U.S. Department of Health and Human Service, National Institutes for Health Research and Development Cluster, Cancer Control, Assistance Listing #93.399; Lack Inadequate Documentation and Lack of Independent Review of Expenditures Corrective Action: We agree with the recommendation...
Finding 2025-002: U.S. Department of Health and Human Service, National Institutes for Health Research and Development Cluster, Cancer Control, Assistance Listing #93.399; Lack Inadequate Documentation and Lack of Independent Review of Expenditures Corrective Action: We agree with the recommendation. We do currently require complete supporting documentation for all expenditures. MCC has updated the Financial Process Procedure to include language related to receipt management, and allowable and disallowed grant expenses. MCC has created a Travel Reimbursement Procedure that addresses approval of Director expenses. Timeline: This was implemented on December 1, 2025. Responsible Parties: MCC Director, Principal Investigators
Finding 2025-001: U.S. Department of Health and Human Service, National Institutes for Health Research and Development Cluster, Cancer Control, Assistance Listing #93.399; Lack of Required Written Policies Corrective Action: We agree with the recommendation. We do currently require complete supporti...
Finding 2025-001: U.S. Department of Health and Human Service, National Institutes for Health Research and Development Cluster, Cancer Control, Assistance Listing #93.399; Lack of Required Written Policies Corrective Action: We agree with the recommendation. We do currently require complete supporting documentation for all expenditures. Montana Cancer Consortium (MCC) has updated the Financial Process Procedure to include language related to receipt management, allowable and disallowed grant expenses, and timing of payment requests. Timeline: This was implemented on December 1, 2025. Responsible Parties: MCC Director, Principal Investigators
We concur with the auditor’s findings. The Organization will develop written procedures for preparing, certifying, and submitting annual federal financial reports, including deadlines and responsible staff.
We concur with the auditor’s findings. The Organization will develop written procedures for preparing, certifying, and submitting annual federal financial reports, including deadlines and responsible staff.
The University identified certain automated COD communication and reporting rules in the Student Information System (SIS) that were not functioning properly during the 2024-2025 aid year. The breakdown of these automated rules required manual interventions to have all Pell Grant disbursements and R2...
The University identified certain automated COD communication and reporting rules in the Student Information System (SIS) that were not functioning properly during the 2024-2025 aid year. The breakdown of these automated rules required manual interventions to have all Pell Grant disbursements and R2T4 adjustments reported to COD, in certain cases exceeding the 15-day requirement. The University has re-trained all financial aid staff to ensure the export process to COD is now completed after each R2T4 adjustment calculation. In addition, the financial aid office now has a dedicated employee running this process at minimum twice a week to ensure that all Pell records get successfully captured and reported to COD within the 15 day window.
Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that Key Line Items are reviewed and accurately reported to Department of Education as required by regulations. ...
Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that Key Line Items are reviewed and accurately reported to Department of Education as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding resulted from inaccuracies introduced through enhancements made to a Workday-delivered report, which ultimately did not produce correct information. Going forward, we will review and validate the Workday report to ensure it aligns with Student Accounts’ reports and accurately reflects tuition and fees for the academic year. Name(s) of the contact person(s) responsible for corrective action: Jacob Witt, AVP of Financial Aid, 703-284-1532 Planned completion date for corrective action plan: June 2026 If the U.S. Department of Education have questions regarding this plan, please contact the individual(s) noted above.
Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its return of Title IV fund procedures to ensure that calculations are performed with correct inputs as required by regulations. Explanation of dis...
Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its return of Title IV fund procedures to ensure that calculations are performed with correct inputs as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding was driven by incorrect MSMS program start and end dates configured in the University’s new Student Information System (Workday). When processing Return of Title IV (R2T4) calculations, Workday relies on the program start and end dates stored in the system. Due to these dates being incorrect, the R2T4 process calculated an inaccurate number of days enrolled, which resulted in an incorrect earned percentage of Title IV aid and, consequently, an incorrect amount of aid the student was eligible to retain. To address this issue, the University has implemented internal controls to review and verify the start and end dates of each academic year in Workday prior to the start of each semester. In addition, an internal control has been added to ensure the start and end dates of each academic year are reviewed and validated as part of the Return of Title IV processing. Name(s) of the contact person(s) responsible for corrective action: Jacob Witt, AVP of Financial Aid, 703-284-1532 Courtney Carey, University Registrar, 703-284-1523 Planned completion date for corrective action plan: Completed December 2025.
Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation ...
Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The findings were primarily driven by the University’s transition to a new Student Information System (Workday), including the Workday-delivered National Student Clearinghouse (NSC) integrations. These constraints resulted in delays and gaps in enrollment reporting processes, increased processing timelines with the National Student Clearinghouse (NSC), and impacted the timely and accurate transmission of enrollment data to the National Student Loan Data System (NSLDS). In response, Marymount University has developed a formal Standard Operating Procedure (SOP) for National Student Clearinghouse reporting and has begun implementing these procedures during the 2025–2026 academic year. Name(s) of the contact person(s) responsible for corrective action: Courtney Carey, University Registrar, 703-284-1523 Jacob Witt, AVP of Financial Aid, 703-284-1532 Planned completion date for corrective action plan: Completed December 2025.
The Institution implements a formal validation and review process for all Quarterly Progress Reports. As part of this corrective action: • Copies of all checks and/or disbursements included in the report will be attached to each Quarterly Progress Report. • All reported expenditures will be verified...
The Institution implements a formal validation and review process for all Quarterly Progress Reports. As part of this corrective action: • Copies of all checks and/or disbursements included in the report will be attached to each Quarterly Progress Report. • All reported expenditures will be verified against the Institution’s accounting system. • Each Quarterly Progress Report will be reviewed, verified, and certified by the President of the Institution or the Compliance Officer prior to submission to COR3/FEMA. Implementation Plan: • Develop and formalize a written procedure for the preparation, validation, and review of Quarterly Progress Reports. • Designate a responsible official to perform an independent review of the report. • Require supporting documentation, including copies of checks and accounting system reports, as mandatory attachments. • Obtain written certification and signature from the President or Compliance Officer prior to submission. IMPLEMENTATION DATE Immediately RESPONSIBLE PERSON Compliance Officer President of the Institution
Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: Implementation of a formal procurement and suspension and debarment policy that includes procedures over review of the federal suspension and debarred listing, that is in compliance with the Uniform Gui...
Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: Implementation of a formal procurement and suspension and debarment policy that includes procedures over review of the federal suspension and debarred listing, that is in compliance with the Uniform Guidance. Procurement policy should include general procurement standards as described by the Uniform Guidance, that include standards on conduct covering conflicts of interest; method of procurement for micro-purchases, small purchases, sealed bids, and proposals; and all other criteria as outlined in 2CFR 200.318 through 200.327. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will develop and implement a procurement policy that is in compliance with the Uniform Guidance. Name(s) of the contact person(s) responsible for corrective action: Sydney Falk, CFO Planned completion date for corrective action plan: February 28, 2026
NSLDS Reporting Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in ...
NSLDS Reporting Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During a typical reporting cycle, all students’ degree information is transmitted to the National Student Clearinghouse (NSC) through a standardized report generated by our Student Information System (Workday). In the instance identified, one student’s graduation status was still pending at the time we submitted degree records for all May 2025 graduates. Once the student’s status was finalized and the degree was officially conferred, we submitted the student’s information manually to the NSC. However, the degree conferral date was reported incorrectly; the actual conferral date was submitted instead of the last day of the student’s final term, which is the required standard. To prevent this issue from recurring, we will discontinue all manual degree submissions to the NSC. Going forward, we will rely exclusively on Workday-generated reports to ensure that all graduation dates are accurate, consistent, and aligned with institutional reporting standards. Name(s) of the contact person(s) responsible for corrective action: James Patton, Assistant Vice President for Academic Affairs and University Registrar Planned completion date for corrective action plan: This change in our data-reporting procedure has already been implemented. The updated process was in place for the most recent degree verification cycle, which was reported to the National Student Clearinghouse on 01-02-2026. If the U.S. Department of Education has questions regarding these plans, please call Dawn Durham at 864-294-2429.
The Village Mayor will provide an updated policy to be approved by the Village Board in 2026.
The Village Mayor will provide an updated policy to be approved by the Village Board in 2026.
Management has currently implemented procedures to have sliding fee application information reconciled to the applicable information in the billing system.
Management has currently implemented procedures to have sliding fee application information reconciled to the applicable information in the billing system.
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