Corrective Action Plans

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Management is cognizant of this limitation and will implement additional procedures where possible.
Management is cognizant of this limitation and will implement additional procedures where possible.
Corrective Action: See above corrective action plans for 2024-001 and 2024-002. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance Jason Kowarsch, Registrar
Corrective Action: See above corrective action plans for 2024-001 and 2024-002. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance Jason Kowarsch, Registrar
Corrective Action: Here are the immediate corrective actions taken: • There are now appropriate staffing levels in the Records office. Training is up-to-date as well. • A thorough review of the reporting requirements and a step-by-step guide was made by ITS and the Registrar to ensure NSC reports ...
Corrective Action: Here are the immediate corrective actions taken: • There are now appropriate staffing levels in the Records office. Training is up-to-date as well. • A thorough review of the reporting requirements and a step-by-step guide was made by ITS and the Registrar to ensure NSC reports are correct and meet the NSC requirements. • The missing NSLDS reports for the 2022-2023 academic year have been prepared and submitted. 2023-24 academic year were prepared and submitted as of 2/11/2025. The 2024-2025 academic year will be prepared and submitted by the end of the Spring 2025 semester. • Coordination with the NSC representatives to ensure the validity and accuracy of the reports in compliance with submission requirements and verification of report acceptance. To prevent future occurrences of missed NSLDS reporting, the following steps have been implemented: • Responsibility: The registrar is the primary reporting coordinator to the National Student Clearinghouse, with support from both Student Financial Services and ITS. • Automated Reminders: Calendar alerts and task management reminders are sent monthly to notify responsible staff well in advance of reporting deadlines this includes the Registrar, Student Financial Services and ITS. • Training and Documentation: A standard operating procedure (SOP) has been documented to guide future reporting efforts. However, ITS must make it a priority when there are changes to NSC reporting requirements. This was lacking during the 2022-2024 periods the university failed to report. • Management Oversight: The Vice President for Academic Administration must also ensure that all these processes and departments are working to ensure the student data is being reported correctly and on-time. We are confident that these measures will address the issue of failure to report to the NSC and ensure full compliance with NSLDS reporting requirements in the future. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance Jason Kowarsch, Registrar Completion Date: February 11, 2025
Corrective Action: Financial aid will be processed on or after census day (12th day of enrollment period) for all students identified by the Registrar and financially cleared as enrolled as of that date. The Registrar will ensure students listed as enrolled as of census date, are registered and att...
Corrective Action: Financial aid will be processed on or after census day (12th day of enrollment period) for all students identified by the Registrar and financially cleared as enrolled as of that date. The Registrar will ensure students listed as enrolled as of census date, are registered and attending classes. Student Finance has learned to identify anomalies within the Ellucian system that caused the system to not auto-adjust to account for student eligibility. More staff training will be done in Student Finance to review awarding, to prevent this as an ongoing issue. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance Jason Kowarsch, Registrar Completion Date: To be completed by June 1, 2025
Finding 2024-002 Name of Responsible Individual: James Slizewski, Registrar Corrective Action: The University has implemented several corrective actions to address this finding. We have created a comprehensive process document to ensure accurate reporting of student enrollment changes. This document...
Finding 2024-002 Name of Responsible Individual: James Slizewski, Registrar Corrective Action: The University has implemented several corrective actions to address this finding. We have created a comprehensive process document to ensure accurate reporting of student enrollment changes. This document outlines each step of the reporting process in detail, providing clear guidelines and procedures for staff to follow for each type of enrollment report that is required. This document will also outline a procedure for conducting reviews of student status changes to ensure they align with our reported data. These reviews will involve cross-checking the information in our reporting system with data generated by our student information system’s delivered enrollment reporting process to identify discrepancies prior to submitting the report. Additionally, we are seeking training and outside consultation on how to better utilize our student information system more effectively. We will engage with consultants to improve our student information system’s delivered student withdrawal and enrollment reporting processes. By utilizing our student information system’s delivered processes more effectively, we will reduce future enrollment reporting errors. Anticipated Completion Date: February 2025
Finding 2024-001 Name of Responsible Individual: Alexis Ritter, Director of Cash Management Corrective Action: To prevent similar occurrences in the future, we will transition from monthly program reconciliations to weekly FSEOG reconciliations and bi-weekly FWS reconciliations, which will allow for...
Finding 2024-001 Name of Responsible Individual: Alexis Ritter, Director of Cash Management Corrective Action: To prevent similar occurrences in the future, we will transition from monthly program reconciliations to weekly FSEOG reconciliations and bi-weekly FWS reconciliations, which will allow for more effectively monitoring of award reversals or negative adjustments. Upon completion of these reconciliations, any excess cash identified will be promptly returned via G-5. Additionally, we will explore the feasibility of automating the notification process for negative adjustments posted in the ERP system, ensuring that we can capture excess cash in a more timely manner. Anticipated Completion Date: February 2025
Finding 537462 (2024-003)
Significant Deficiency 2024
Corrective Action Plan 2024-003: The University concurs with the finding and has made the required corrections to the COD disbursement dates. The University process when posting Aid has remained consistent each year, this appears to be an isolated incident where CAMS did not pick up the date listed ...
Corrective Action Plan 2024-003: The University concurs with the finding and has made the required corrections to the COD disbursement dates. The University process when posting Aid has remained consistent each year, this appears to be an isolated incident where CAMS did not pick up the date listed on the disbursement screen for these students and pass that to COD. The University has implemented a control to complete the disbursements each time and then verify the date reflects correctly in COD afterwards. While this should be an automatic process, and has been in previous years, it will be something the University verifies now with each aid posting. Completion Date: August 2024 Contact Person: Megan Morton, Director of Financial Services
Finding 537461 (2024-002)
Significant Deficiency 2024
Corrective Action Plan 2024-002: The University concurs with the finding. The University has corrected the two Spring 2024 RT24 calculations and initiated additional Pell grant disbursements to the noted students. The University has updated its calculations of the scheduled breaks for the 2024-2025 ...
Corrective Action Plan 2024-002: The University concurs with the finding. The University has corrected the two Spring 2024 RT24 calculations and initiated additional Pell grant disbursements to the noted students. The University has updated its calculations of the scheduled breaks for the 2024-2025 academic year. Completion Date: August 2024 Contact Person: Megan Morton, Director of Financial Services
Commonwealth: Direct Loan processor will submit monthly reconciliations to Executive Director of Financial Aid or designated campus director for review and approval
Commonwealth: Direct Loan processor will submit monthly reconciliations to Executive Director of Financial Aid or designated campus director for review and approval
ESU: The University acknowledges this is a repeat finding. While a corrective action plan was implemented in May 2024, the audit sample consisted of students from Fall 2023 and Spring 2024, before the updated procedures were in effect. Since then, the University has enhanced its process for identify...
ESU: The University acknowledges this is a repeat finding. While a corrective action plan was implemented in May 2024, the audit sample consisted of students from Fall 2023 and Spring 2024, before the updated procedures were in effect. Since then, the University has enhanced its process for identifying when a student ceases participation in a course. Faculty are now required to indicate when a student stops attending. If a faculty member and student agree on issuing an incomplete grade, both must sign a document attesting that the incomplete is a valid final grade. This ensures clarity for the Registrar's Office. Registrar staff now update the National Student Clearinghouse promptly once a student’s last date of activity is confirmed, particularly when a student withdraws from all courses. This process supports timely compliance with the 60-day federal reporting requirement. Additionally, the University is reviewing its procedures for reporting program enrollment effective dates to ensure consistency with NSLDS standards. All updates are submitted through the National Student Clearinghouse. IUP: IUP will set guidelines that all degree clearing must be done with the 45 day time line so the students are reported within the 60 days limit Cheyney: Cheyney University of Pennsylvania extracts current enrollment information, including any enrollment status changes for all students from the University system of record based on the schedule timeline provided to NSC. As of Fall 2024, The Registrar’s Office continues to review NSC information following transmission, particularly for effective dates of completely withdrawn students. The NSC reports enrollments to NSLDS for the University. Cheyney University had previously learned that NSLDS did not receive students' enrollment status changes from NSC in a timely manner due the University HCM2 status and timing of students being reported to NSLDS from COD based on Ed’s approval of the University HCM2 submissions Kutztown: We will shorten our process to 2-3 days to compensate from the (up to) 30 day lag between NSC reporting and NSLDS reporting. We will connect with another PASSHE school (not on the findings report) to ascertain how they keep their submissions timely, and learn best practices. We will renew our cooperative efforts with financial aid to ensure both sides of the equation – NSC and NSLDS – are communicating and that both offices are involved in double checking. Commonwealth: The issues with enrollment reporting were one-time issues related to the integration of the three schools and the implementation of and data migration to a new student information system. Issues have been resolved and Commonwealth University is currently reporting on the prescribed schedule Millersville: The Registrar’s Office will evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the University’s last date of attendance. Primarily, the frequency of submissions to the NSC.
ESU: The University acknowledges this is a repeat finding. In response, updated policies and procedures were implemented in May 2024. The audit sample included students from Fall 2023 and Spring 2024—periods that predated the implementation of the corrective measures. To improve compliance, the Univ...
ESU: The University acknowledges this is a repeat finding. In response, updated policies and procedures were implemented in May 2024. The audit sample included students from Fall 2023 and Spring 2024—periods that predated the implementation of the corrective measures. To improve compliance, the University has introduced enhanced reporting mechanisms to identify when a student is no longer participating in any enrolled courses during a given semester. Once a determination is made that a student has withdrawn, University Registrar staff manually update the student’s status in the National Student Clearinghouse. This process reduces the delay between a student’s actual withdrawal and the status update reported to NSLDS. These steps are intended to ensure timely and accurate reporting moving forward. IUP: IUP will set guidelines that all degree clearing must be done with the 45 day time line so the students are reported within the 60 days limit. Cheyney:Cheyney University of Pennsylvania utilizes the National Student Clearinghouse as a third-party service provider for enrollment reporting and provides all enrollment data to NSC, believing that enrollment would be reported to NSLDS in compliance with federal regulations; unfortunately, the enrollment data from the NSC roster which is provided to National Student Loan Data Systems (NSLDS), is only matched to students who currently have existing enrollment records in NSLDS. Student enrollment information is provided to NSLDS from Common Originations and Disbursements (COD). Cheyney University is a Heightened Cash Monitoring 2 (HCM2) institution, and students' Title IV aid/ disbursements are reported differently than advance pay institutions. The student records from COD are only provided to NSLDS upon approval of disbursement from Ed after the University HCM2 submissions are approved. As of Fall 2024, Cheyney University has continued to directly report and upload enrollment for all Title IV recipients to NSLDS from the monthly NSC enrollment rosters. Kutztown: We will target shortening our status change reporting process to 2-3 days to compensate from the (up to) 30 day lag between NSC reporting and NSLDS reporting. We will connect with another PASSHE school that was on the findings report for the last period - but not this period - to ascertain how they avoided the repeat, and to learn additional best practices. We will renew our cooperative efforts with financial aid to ensure both sides of the equation – NSC and NSLDS – are communicating and that both offices are involved in double checking Commonwealth: The issues with enrollment reporting were one-time issues related to the integration of the three schools and the implementation of and data migration to a new student information system. Issues have been resolved and Commonwealth University is currently reporting on the prescribed schedule. Millersville: The Registrar’s Office will review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Primarily, the frequency of submissions to the NSC.
Finding 537455 (2024-001)
Significant Deficiency 2024
Views of Responsible Officials and Planned Corrective Actions: We are committed to strengthening our internal controls and procedures to ensure full compliance with Uniform Guidance requirements. We also acknowledge that the audit waiver BRAC Bangladesh received from the USAID Mission in Bangladesh ...
Views of Responsible Officials and Planned Corrective Actions: We are committed to strengthening our internal controls and procedures to ensure full compliance with Uniform Guidance requirements. We also acknowledge that the audit waiver BRAC Bangladesh received from the USAID Mission in Bangladesh was not sufficient to exempt them from conducting a program-specific audit of the Department of State (BPRM) funded project, SPRMCO23CA0152. In response to the finding, BRAC Bangladesh has already conducted an audit of the project, which demonstrated that the financial statements and schedule of expenditures were free from material misstatements. Moving forward, we will amend our subagreement templates to include specific language around USG audit requirements, and the submission of audit reports will be included in the reporting section of the agreements. We will also update our Fiscal Policies and Procedures Manual to formalize the process for receiving and reviewing audit reports, and establishing follow-up procedures to resolve potential audit findings. We will also maintain clear documentation of the submission, review, and follow up of audits.
Noncompliance with Reporting Requirements
Noncompliance with Reporting Requirements
Criteria: Preble Street and Subsidiary’s major federal program carries with it certain periodic reporting requirements that are due 30 days following the close of each quarter.
Criteria: Preble Street and Subsidiary’s major federal program carries with it certain periodic reporting requirements that are due 30 days following the close of each quarter.
Condition: We noted one instance in which a required quarterly report for ALN 93.323 was submitted after the required deadline.
Condition: We noted one instance in which a required quarterly report for ALN 93.323 was submitted after the required deadline.
Questioned Costs: None
Questioned Costs: None
Context: With regards to ALN 93.323, the quarterly Case Management and MaineCare Unwinding reports for the quarter ended May 2024 was submitted one day past the 30 day deadline following the close of the quarter.
Context: With regards to ALN 93.323, the quarterly Case Management and MaineCare Unwinding reports for the quarter ended May 2024 was submitted one day past the 30 day deadline following the close of the quarter.
Effect: None
Effect: None
Cause: Staff turnover and management oversight.
Cause: Staff turnover and management oversight.
Repeat Finding: Yes
Repeat Finding: Yes
Recommendation: We encourage Preble Street and Subsidiary to continue its efforts to ensure that all contract reports are submitted timely in the future.
Recommendation: We encourage Preble Street and Subsidiary to continue its efforts to ensure that all contract reports are submitted timely in the future.
Views of responsible officials and planned corrective action: We are in agreement with the finding. Management is in the process of creating an updated process/system to ensure compliance with this requirement moving forward.
Views of responsible officials and planned corrective action: We are in agreement with the finding. Management is in the process of creating an updated process/system to ensure compliance with this requirement moving forward.
STEM - PODER – Federal Assistance Listing Number 84.031C Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for suspension and debarment to ensure the University is following requirements. Explanation of disagreemen...
STEM - PODER – Federal Assistance Listing Number 84.031C Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for suspension and debarment to ensure the University is following requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is in the process of developing and implementing a formal policy and procedure to verify that a vendor is not debarred or suspended in the System for Award Management (SAM) database. The procedure, which will be in place by the end of FY 2025, will outline roles, responsibilities, and documentation requirements to ensure consistent compliance. Name(s) of the contact person(s) responsible for corrective action: Diane DiStaulo, Director of Accounting Operations, (201) 761-7415 Planned completion date for corrective action plan: by the end of FY2025
Student Financial Aid Cluster – Federal Assistance Listing Numbers 84.007, 84.033, 84.063 and 84.268 Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 ...
Student Financial Aid Cluster – Federal Assistance Listing Numbers 84.007, 84.033, 84.063 and 84.268 Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has developed a policy to identify uncashed Title IV refund checks prior to the 240-day expiration date. The policy includes steps to contact students whose checks did not clear and to return the refunds to the Department within 240 days after the issue date of the check. The procedures will ensure that reviews are completed and returned timely according to applicable regulations. Name(s) of the contact person(s) responsible for corrective action: Lillian Perreira-Talty, Director of Student Accounts (201) 761-6080 Planned completion date for corrective action plan: Completed
View Audit 348651 Questioned Costs: $1
Student Financial Aid Cluster – Federal Assistance Listing Numbers 84.063 and 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review ...
Student Financial Aid Cluster – Federal Assistance Listing Numbers 84.063 and 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has updated its policies and procedures for NSLDS submissions via their third-party servicer to ensure relavant information is being captured and reported timely in accordance with applicable regulations. Name(s) of the contact person(s) responsible for corrective action: Kamla Singh-Ramoutar, University Registrar, (201) 761-6051 Planned completion date for corrective action plan: Completed
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