Audit 18249

FY End
2022-09-30
Total Expended
$5.98M
Findings
2
Programs
3
Year: 2022 Accepted: 2023-06-29

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
22245 2022-001 - - C
598687 2022-001 - - C

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $5.72M Yes 1
84.425 Education Stabilization Fund $190,073 Yes 0
84.033 Federal Work-Study Program $69,970 Yes 0

Contacts

Name Title Type
FLMHVHEDMUF8 Phil Lundberg Auditee
5035233443 Ian Gelfand Auditor
No contacts on file

Notes to SEFA

Accounting Policies: 1. Significant Accounting Policies Basis of Accounting - The schedule of expenditures of federal awards of Oregon College of Oriental Medicine (the College) has been prepared using the accrual basis of accounting in accordance with accounting principles generally accepted in the United States of America. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance).The College also coordinates a guaranteed student loan program funded by the U.S. Department of Education. The amount reported on the schedule of expenditures of federal awards with respect to the student loan program represents total loans received by students of the College under the program. Because this schedule presents only a selected portion of the operations of the College, it is not intended to, and does not, present the financial position, changes in net assets, or cash flows of the College. Pass-through grantor identifying numbers (if applicable) are presented where available. Expenditures - Expenditures reported on the schedule are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The College has not elected to use the 10 percent de minimis indirect cost rate. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate.

Finding Details

Finding 2022-001 Student Financial Assistance Cluster of Programs Cash Management 84.268 Federal Direct Loan Program U.S. Department of Education Criteria: 34 CFR 668.162 (b)(3) The institution must disburse the Title IV funds requested as soon as administratively feasible but no later than three business days following the date the institution received those funds. Condition: A sample of thirty-seven students was selected for student file and account testing. Two students had their direct loan funds applied to their account four business days after they were drawn down from G5. When the drawdowns and disbursements were examined, it was noted that a total of sixteen disbursements for a total of $128,161 were applied to student accounts after four business days. Context: The deficiency was discovered during the audit testing of student files and accounts. Effect: Because the loans were unsubsidized and PLUS loans, the effect of this issue to the students would be in the form of interest accrued prior to the students having access to the funds. However, due to the COVID-19 pandemic, interest accruals on loans had been suspended and, as such, no interest was accrued during this period. Cause: These appeared to be isolated incidents where the balance was drawn a day earlier than other similar disbursement cycles. Recommendation: We recommend that the College update their internal documentation review of Title IV drawdown funds in order to prevent early draws. Views of responsible officials: We concur with this finding. This finding was due to human error. The spreadsheet was copied from the last year, and dates were updated to be the current year. The past year may have had a holiday which caused the G5 funds to be received an additional day before the disbursement date. When updating the dates to the current year, the four-day period was not caught. The form was only reviewed by the Director of Financial Aid. To prevent this error from occurring in the future, three members of the Finance Team will review the disbursement schedule so that there are always multiple personnel reviewing the dates. These three members will include the Director of Financial Aid, and any two of the following: Accounting Manager, Staff Accountant, Registrar, or Business Office and Bookstore Manager.
Finding 2022-001 Student Financial Assistance Cluster of Programs Cash Management 84.268 Federal Direct Loan Program U.S. Department of Education Criteria: 34 CFR 668.162 (b)(3) The institution must disburse the Title IV funds requested as soon as administratively feasible but no later than three business days following the date the institution received those funds. Condition: A sample of thirty-seven students was selected for student file and account testing. Two students had their direct loan funds applied to their account four business days after they were drawn down from G5. When the drawdowns and disbursements were examined, it was noted that a total of sixteen disbursements for a total of $128,161 were applied to student accounts after four business days. Context: The deficiency was discovered during the audit testing of student files and accounts. Effect: Because the loans were unsubsidized and PLUS loans, the effect of this issue to the students would be in the form of interest accrued prior to the students having access to the funds. However, due to the COVID-19 pandemic, interest accruals on loans had been suspended and, as such, no interest was accrued during this period. Cause: These appeared to be isolated incidents where the balance was drawn a day earlier than other similar disbursement cycles. Recommendation: We recommend that the College update their internal documentation review of Title IV drawdown funds in order to prevent early draws. Views of responsible officials: We concur with this finding. This finding was due to human error. The spreadsheet was copied from the last year, and dates were updated to be the current year. The past year may have had a holiday which caused the G5 funds to be received an additional day before the disbursement date. When updating the dates to the current year, the four-day period was not caught. The form was only reviewed by the Director of Financial Aid. To prevent this error from occurring in the future, three members of the Finance Team will review the disbursement schedule so that there are always multiple personnel reviewing the dates. These three members will include the Director of Financial Aid, and any two of the following: Accounting Manager, Staff Accountant, Registrar, or Business Office and Bookstore Manager.