Corrective Action Plans

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Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The Executive Director of Financial Aid and the Assistant Director of Compliance & Reporting will provide regular in-house R2T4 training specific to WBU for all financial aid staff. All financial aid staff responsible...
Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The Executive Director of Financial Aid and the Assistant Director of Compliance & Reporting will provide regular in-house R2T4 training specific to WBU for all financial aid staff. All financial aid staff responsible for R2T4 will be required to complete pertinent training provided by FSA and purchased through NASFAA. In addition, financial aid staff responsible for R2T4 have established procedures to ensure the accurate and timely Return of Title IV Funds. To address the system limitations identified, the University has acquired a new Software-as-a-Service (SaaS) financial aid management system. Person Responsible for Corrective Action Plan: Executive Director of Financial Aid, Robert Hamilton, and Assistant Director of Compliance & Reporting, Brooke Tyler, and Assistant Director of Financial Aid, Alyssa Shealor Anticipated Date of Completion: June 30, 2026
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: WBU has entered into an agreement with Ellucian to implement Ellucian Student powered by Colleague as the new student information system. WBU will start utilizing this new student information syste...
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: WBU has entered into an agreement with Ellucian to implement Ellucian Student powered by Colleague as the new student information system. WBU will start utilizing this new student information system in April 2026. WBU will utilize the built-in functionality and tools to report to NSLDS at that time which should correct this issue completely. We will continue to work towards compliance with NSLDS reporting requirements through the following action plan: An internal SSRS report for official and unofficial withdrawals which accurately reflects withdrawn students remains available to the WBU offices of Financial Aid and the Registrar for verification as part of the planned corrective action. The custom NSC reporting tool(s) will continue to be updated to make sure the correct combination of fields and corresponding data sources are reported as accurately as possible. WBU will continue to work with NSC to mitigate issues related to data not transferring correctly between NSC and NSLDS. • A field-by-field analysis plus any needed corrections to the queries will be performed. o By default, term "W" withdrawals are reconsidered by the updated tool each time a report is generated for NSC. o Some date fields have been corrected that were previously misunderstood by the custom tool's historical authors. o Post-submission error corrections by registrar staff via NSC's website are spot-checked by Information Technology when requested. o If certain data issues cannot be resolved satisfactorily via NSC alone, then corrective measures via NSLDS directly may be considered. o The PowerCampus 9.1.2 baseline product's NSC reporting tool was determined to be insufficient for timely and accurate reporting to NSC with WBU's current data on several counts. WBU has upgraded the PowerCampus system to version 9.2.3 and will continue to work towards a solution for the baseline reporting tool with the upgraded system.  Some of the recurring data updates needed before running the PC baseline tool, are still being run periodically as a source data benefit for the custom tool. Person Responsible for Corrective Action Plan: Chief Information Officer, Cagan Cummings Anticipated Date of Completion: Ongoing
Need Analysis Planned Corrective Action: The Assistant Director of Compliance & Reporting developed reports to help identify any students who were not properly offered the subsidized loan which was reviewed before the start of the first term of the current academic year. In addition, the reports wil...
Need Analysis Planned Corrective Action: The Assistant Director of Compliance & Reporting developed reports to help identify any students who were not properly offered the subsidized loan which was reviewed before the start of the first term of the current academic year. In addition, the reports will be reviewed periodically throughout the aid year to identify enrollment or academic record changes that may affect loan eligibility. When discrepancies are identified, loan offers will be adjusted promptly to ensure compliance with federal loan limits. These corrective actions strengthen oversight, improve accuracy in loan awarding, and enhance internal controls to prevent recurrence of this issue. To address the system limitations identified, the University has acquired a new Software-as-a-Service (SaaS) financial aid management system. Person Responsible for Corrective Action Plan: Executive Director of Financial Aid, Robert Hamilton, and Assistant Director of Compliance & Reporting, Brooke Tyler Anticipated Date of Completion: June 30, 2026
Views of Responsible Officials and Planned Corrective Action Plan: The Controller meets monthly with IHC management team to review financial statements along with requisitions and approvals for open Po’s/Invoices. During this time, she also reviews whether there are services rendered that were not e...
Views of Responsible Officials and Planned Corrective Action Plan: The Controller meets monthly with IHC management team to review financial statements along with requisitions and approvals for open Po’s/Invoices. During this time, she also reviews whether there are services rendered that were not entered as a requisition or for which we did not receive a check request. The property management team will alter how the requisitions are done. The property manager in the field will send notification to Operations Managers each time a vendor is called to perform a service at the location. The Operations Manager will enter a default requisition to alert the Business Office. This will then be in our system to validate an accrual is made and/or contact vendor or IHC staff to obtain invoices from vendor. There are some vendors who are smaller or less automated in their own processes. This sometimes creates a large gap from time service if performed to when they invoice Inglis.
Response and Corrective Action Plan: The District will annually prepare the indirect cost charged to the program based on the actual fiscal year trial balance. The District will provide an estimate to the Board each June to ensure proper approval of fund transfers.
Response and Corrective Action Plan: The District will annually prepare the indirect cost charged to the program based on the actual fiscal year trial balance. The District will provide an estimate to the Board each June to ensure proper approval of fund transfers.
Views of Responsible Officials and Corrective Action Plan 2025-001 –Procurement, Suspension and Debarment Cluster / Program: Research & Development (R&D) / ALN 19.UO9, 19.U10: The MITRE Corporation – U.S. Department of State Grantor: - Defense Advanced Research Projects Agency (DARPA) / DoD, Nationa...
Views of Responsible Officials and Corrective Action Plan 2025-001 –Procurement, Suspension and Debarment Cluster / Program: Research & Development (R&D) / ALN 19.UO9, 19.U10: The MITRE Corporation – U.S. Department of State Grantor: - Defense Advanced Research Projects Agency (DARPA) / DoD, National Science Foundation (NSF) / U.S. Department of State Award Name: EE Tang MPI PennST DARPA Monolithic GaN, Social Networks and Migration in Nepal / Conflict Observatory – Sudan, Conflict Observatory – Ukraine Award Number: AWD0011529, AWD0007921 / AWD0011946, AWD0010905 Award Year: FY2025 Assistance Listing Numbers: 12.910, 47.075 / 19.U09, 19.U10 Assistance Listing Titles: Research and Technology Development, Social, Behavioral, and Economic Sciences / U.S Department of State Pass-Through Entities: N/A / Pennsylvania State University The University acknowledges the need for consistent application of policies and procedures to ensure compliance with 2 CFR 200.214. The university performed a root cause analysis and determined that these identified issues were human error due to the manual nature of the established process. The University reviewed the three identified vendors and concluded that they were not debarred at the time of the transaction. Outlined below are steps that the university will take or have taken to improve our processes and procedures:  As of June 2025, Yale has implemented the Supplier Gateway Portal, introducing an enhanced, automated process for supplier onboarding. New suppliers established through the portal are automatically screened for debarment without manual involvement. Subsequently, the supplier’s information is transferred weekly to the Visual Compliance system, which performs continuous debarment monitoring. Yale is proactively notified via email should any changes in a supplier's status occur.  The university provided training to the full team responsible for these activities with the rollout of the Supplier Gateway Portal. This was completed June 2025. University contact: Rodney Brunson, Director, Accounts Payable & Payment Services Rodney.Brunson@yale.edu
B. Comment on Findings and Recommendations We concur with the auditor's finding that HANDS Metro's funds were used to fund the HANDS Triad Housing insurance audit escrow. We had a new employee and they made a mistake and it was not found until the assistant controller reviewed the ledgers 2 weeks la...
B. Comment on Findings and Recommendations We concur with the auditor's finding that HANDS Metro's funds were used to fund the HANDS Triad Housing insurance audit escrow. We had a new employee and they made a mistake and it was not found until the assistant controller reviewed the ledgers 2 weeks later (which happened to be past year end). This was not an intentional transaction to use a different properties funds to put into an escrow account, it was a mistake. The funds have since been transferred back to HANDS Metro. C. Actions Taken or Planned The Assistant Controller and Property Accountant will review all funds were paid from the correct account before the transfer is completed in the bank account.
B. Comment on Findings and Recommendations We concur with the auditors' finding that the balance in excess residual receipts was above the limit allowed by HUD and was not remitted per HUD's guidelines. C. Actions Taken or Planned The Assistant Controller and Property Accountant will review and veri...
B. Comment on Findings and Recommendations We concur with the auditors' finding that the balance in excess residual receipts was above the limit allowed by HUD and was not remitted per HUD's guidelines. C. Actions Taken or Planned The Assistant Controller and Property Accountant will review and verify the Residual Receipts balance, determine amount eligible for retainage and return the remainder to HUD in accordance with current regulations.
B. Comment on Findings and Recommendations We concur with the auditor's finding that HANDS Metro's funds were used to fund the HANDS Triad Housing insurance audit escrow. We had a new employee and they made a mistake and it was not found until the assistant controller reviewed the ledgers 2 weeks la...
B. Comment on Findings and Recommendations We concur with the auditor's finding that HANDS Metro's funds were used to fund the HANDS Triad Housing insurance audit escrow. We had a new employee and they made a mistake and it was not found until the assistant controller reviewed the ledgers 2 weeks later (which happened to be past year end). This was not an intentional transaction to use a different properties funds to put into an escrow account, it was a mistake. The funds have since been transferred back to HANDS Metro. C. Actions Taken or Planned The Assistant Controller and Property Accountant will review all funds were paid from the correct account before the transfer is completed in the bank account.
B. Comment on Findings and Recommendations We concur with the auditors' finding that the balance in excess residual receipts was above the limit allowed by HUD and was not remitted per HUD's guidelines. C. Actions Taken or Planned The Assistant Controller and Property Accountant will review and veri...
B. Comment on Findings and Recommendations We concur with the auditors' finding that the balance in excess residual receipts was above the limit allowed by HUD and was not remitted per HUD's guidelines. C. Actions Taken or Planned The Assistant Controller and Property Accountant will review and verify the Residual Receipts balance, determine amount eligible for retainage and return the remainder to HUD in accordance with current regulations.
Effective immediately, all Title I staff will be completing semi-annual certifications and personnel activity reports as appropriate.
Effective immediately, all Title I staff will be completing semi-annual certifications and personnel activity reports as appropriate.
2025-001 – Special Tests and Provisions - Enrollment Reporting Auditor Description of Condition and Effect. During our testing we noted that one student out of a testing population of twelve did not have their status change reported timely to NSLDS. As a result, there is an increased risk that infor...
2025-001 – Special Tests and Provisions - Enrollment Reporting Auditor Description of Condition and Effect. During our testing we noted that one student out of a testing population of twelve did not have their status change reported timely to NSLDS. As a result, there is an increased risk that information will not be reported to NSLDS on a timely basis. Auditor Recommendation. We recommend that the Organization enhance its policies and procedures regarding enrollment reporting to ensure that reporting is completed timely. Corrective Action. The institution concurs with the finding. The error resulted from a manual data entry into the withdrawn students' records. After consulting with our student information systems provider, we were informed about a Wizard that could accurately update the withdrawn date and prevent future reporting issues. The Registrar and IT have rectified the finding. They will implement a monthly review for withdrawn students to ensure the last day attended is reported accurately and on time. Responsible Person. Amy Howarth Anticipated Completion Date. 09 01 2025
Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No. 21.027 U.S. Department of Treasury Missouri Primary Care Association Criteria or specific requirement – Reporting (2 CFR 200.329) Condition – The Organization’s internal controls over compliance were not able to ensure progress...
Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No. 21.027 U.S. Department of Treasury Missouri Primary Care Association Criteria or specific requirement – Reporting (2 CFR 200.329) Condition – The Organization’s internal controls over compliance were not able to ensure progress reporting required to be submitted to the pass-through entity was completed timely. Cause – The Organization’s internal controls over compliance did not ensure all grant reporting requirements were completed timely. Effect or potential effect – The Organization did not submit the required quarterly and annual performance reports in a timely manner. Questioned costs – None Context – The Organization is required to submit quarterly status reports and an annual performance report to the pass-through entity in a timely manner. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should consider implementing a grant reporting calendar for all grants with reporting requirements. Views of responsible officials and planned corrective actions – In order for this finding not to occur in the future, the Chief Financial Officer will • Create a Grant calendar to track report due dates • Hold quarterly meetings with managers to ensure we have all reports submitted timely in the future Contact person responsible for corrective action – Toby Barnett, Chief Financial Officer Anticipated completion date – December 2025
Management's Response: We concur. Views of Responsible Officials and Corrective Action Plan Response: The two students identified were underpaid due to locks on their financial aid units for either late-start courses or being on an approved SAP appeal plan. Once locks were removed, PowerFAIDS should...
Management's Response: We concur. Views of Responsible Officials and Corrective Action Plan Response: The two students identified were underpaid due to locks on their financial aid units for either late-start courses or being on an approved SAP appeal plan. Once locks were removed, PowerFAIDS should have recalculated their aid to reflect their current units, however that did not happen. As a result, the Pell Grant was under-awarded. The students have now been disbursed with their full Pell eligibility. Corrective Action Plan: The transition from a legacy SIS and PowerFAIDS to a single ERP will consolidate financial aid and enrollment data into a single system, eliminating reliance on manual adjustments and reducing the risk of data discrepancies between two systems. Banner allows for automated and real-time recalculations for enrollment changes such as late start courses, reducing the risk of Pell under or over-awarding. Financial aid staff will receive updated training and guidance on the importance of verifying Pell recalculations when manual locks on student financial aid records are needed, for instance in the case of a student on an approved SAP appeal plan.
The following is the Recruitment and Admissions Corrective Action Plan for the single Audit Finding for FY25. Criteria or Specific Requirement: Special Tests and Provisions – NSLDS Reporting, 34 CFR Sections 690.83 (b)(2) and 685.309. Finding Summary: Student enrollment and program information was n...
The following is the Recruitment and Admissions Corrective Action Plan for the single Audit Finding for FY25. Criteria or Specific Requirement: Special Tests and Provisions – NSLDS Reporting, 34 CFR Sections 690.83 (b)(2) and 685.309. Finding Summary: Student enrollment and program information was not communicated to the National Student Loan Data System (NSLDS) timely or accurately. Officials Responsible for Ensuring Corrective Action: Shanna Pope, Registrar Views of Responsible Officials and Planned Corrective Action: Management concurs with the finding and will implement enhanced procedures to ensure internal controls support the timely and accurate reporting of student status, program, and completion information to the National Student Loan Data System (NSLDS). For each National Student Clearinghouse (NSC) file submitted, students with status, program, or completion changes will be systematically identified and flagged for review. Registrar staff will conduct a targeted, sample-based review of these flagged records directly within NSLDS to verify that data transmitted from NSC was received, processed, and reflected accurately. All policies and procedures governing enrollment reporting and the processing of student status, program, and completion changes will be reviewed, revised as necessary, and formally implemented no later than April 1, 2026, to align with this corrective action.
Condition: Columbus State Community College did not report student status changes accurately for certain students who withdrew during the year. Planned Corrective Action: As a solution to this issue, the Enrollment Services Operations office at Columbus State Community College, currently responsible...
Condition: Columbus State Community College did not report student status changes accurately for certain students who withdrew during the year. Planned Corrective Action: As a solution to this issue, the Enrollment Services Operations office at Columbus State Community College, currently responsible for National Student Clearinghouse (NSC) reporting, will create a report to monitor for any post-semester enrollment changes that occur due to processes such as end-of-semester grade adjustments or the retroactive withdrawal and administrative withdrawal, to make sure that status changes are reported to the NSC in a timely manner. This report will be monitored, and updates will be made monthly, like the enrollment verification reporting cadence that happens during the semester. Contact person responsible for corrective action: Dina Galley Anticipated Completion Date: 03/01/2026
Views of Responsible Officials and Corrective Action Plan The District has implemented a new, fully integrated enterprise resource planning system. This system improves internal controls for data management, enabling us to verify and update enrollment data reported to NSLDS more quickly and accurate...
Views of Responsible Officials and Corrective Action Plan The District has implemented a new, fully integrated enterprise resource planning system. This system improves internal controls for data management, enabling us to verify and update enrollment data reported to NSLDS more quickly and accurately.
Views of Responsible Officials and Corrective Action Plan Each Return of Title IV calculation will be supported by verifiable supporting reports or information demonstrating the number of calendar days used in the calculation. During the annual New Year Roll, all date fields will be manually reviewe...
Views of Responsible Officials and Corrective Action Plan Each Return of Title IV calculation will be supported by verifiable supporting reports or information demonstrating the number of calendar days used in the calculation. During the annual New Year Roll, all date fields will be manually reviewed to ensure default system values are appropriate and consistent with the academic calendar. This information will be reviewed by supervisory personnel independent of the staff member preparing the dates and calculations.
Management's Reponse: We concur. View of Responsible Offiicals and Corrective Action Plan The Financial Aid department has strengthened R2T4 compliance through staff training, system validation, deadline tracking, peer reviews, and internal audits. The Director will also conduct an annual comprehens...
Management's Reponse: We concur. View of Responsible Offiicals and Corrective Action Plan The Financial Aid department has strengthened R2T4 compliance through staff training, system validation, deadline tracking, peer reviews, and internal audits. The Director will also conduct an annual comprehensive review to assess processes, staffing, and systems to ensure ongoing compliance and improvement. Implementation Date: September 2025
Procedures are currently in place to comply with the requirement to send Direct Loan notifications within the regulatory time frame. To support this, the responsible team member will have a weekly reminder added to their Lewis & Clark Outlook work calendar to prompt timely notifications. Management ...
Procedures are currently in place to comply with the requirement to send Direct Loan notifications within the regulatory time frame. To support this, the responsible team member will have a weekly reminder added to their Lewis & Clark Outlook work calendar to prompt timely notifications. Management will also add a weekly reminder to one of the office managers' calendars to assist with ongoing monitoring and compliance checks. Person(s) Responsible: Angela Weaver Timing for Implementation: November 7, 2025
The Financial Aid office conducted a comprehensive internal review in Spring 2025 to verify that our procedures were consistently followed. As a result, management corrected a student’s loan proration calculation to be consistent with current practices, regarding truncating rather than rounding the ...
The Financial Aid office conducted a comprehensive internal review in Spring 2025 to verify that our procedures were consistently followed. As a result, management corrected a student’s loan proration calculation to be consistent with current practices, regarding truncating rather than rounding the fractional percentage (decimal) of loan eligibility for students receiving one-semester loans in their last semester of study. Management corrected the loan proration calculation in accordance with current procedures, and the loan amount was adjusted accordingly, resulting in the institution returning $64 in Federal Unsubsidized loan funds to Federal Student Aid. The student was eligible only for unsubsidized loans. Person(s) Responsible: Angela Weaver Timing for Implementation: November 21, 2025
Management will remind financial aid administrators of their responsibility to maintain internal controls and sign off on all quality assurance measures. Continued reinforcement of these standards will occur during regular department meetings. Person(s) Responsible: Angela Weaver Timing for Implemen...
Management will remind financial aid administrators of their responsibility to maintain internal controls and sign off on all quality assurance measures. Continued reinforcement of these standards will occur during regular department meetings. Person(s) Responsible: Angela Weaver Timing for Implementation: November 21, 2025
Although Financial Aid Administrators pride themselves on their attention to federal guidelines and the administration of student aid, errors can occur. To reinforce our shared commitment, management has expanded quality assurance reviews and incorporated additional training into regular staff meeti...
Although Financial Aid Administrators pride themselves on their attention to federal guidelines and the administration of student aid, errors can occur. To reinforce our shared commitment, management has expanded quality assurance reviews and incorporated additional training into regular staff meetings. As a result of a verification compliance review, a misread number resulted in a higher Student Aid Index (SAI). A student received Direct Subsidized Loan funds in excess of financial need. Since the student is no longer enrolled during the loan period, according to federal aid guidelines, the institution is not required to take any action to eliminate the excess subsidized loan amount. In contrast if, due to an error, a student borrower who was eligible for a Direct Subsidized Loan instead received a Direct Unsubsidized Loan, the institution would have to correct the error, even if the loan period had ended, by submitting a downward adjustment to reduce or eliminate the Direct Unsubsidized Loan, as appropriate, and replacing it with the same amount of Direct Subsidized Loan funds. Person(s) Responsible: Angela Weaver Timing for Implementation: November 21, 2025
We recommend that management verify monthly that reserve deposits agree to the HUD-approved schedule and obtain confirmation from the bank when deposit amounts are changed. Management should also complete the catch-up deposit and retain documentation.
We recommend that management verify monthly that reserve deposits agree to the HUD-approved schedule and obtain confirmation from the bank when deposit amounts are changed. Management should also complete the catch-up deposit and retain documentation.
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