Federal Agency: U.S. Department of Education Assistance Listing Number and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Cash Management Questioned Cost: $55,915 Criteria: 34 CFR 668.162(d) states that under the heightened cash monitoring payment method, an institution must credit a student's ledger account for the amount of Title IV HEA program funds that the student or parent is eligible to receive, and pay the amount of any credit balance due under ? 668.164(h), before the institution submits a request for funds under the provisions of the advance payment method described in paragraphs (b)(1) and (2) of 34 CFR 668.162, except that the institution's request may not exceed the amount of the disbursements the institution has made to the students included in that request. Condition: Of the 75 samples tested, we noted 29 samples (or 39%) where the University did not credit the student?s ledger account before submitting a request for funds. Further, we noted 3 (or 4%) samples where the University made the disbursement beyond 3 days following the receipt of funds. Cause: The University lacks effective controls to ensure compliance with cash management requirements. Effect: The University is noncompliant with cash management requirements. Known questioned costs exist amounting to $55,915. Identification as a repeat finding: 2021-005 Recommendation: The University?s management should review the requirements of the Uniform Guidance and coordinate with its third-party private financial aid consultant in developing and implementing effective controls over compliance with cash management requirements. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Reporting Questioned Cost: $0 Criteria: Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system (OMB No. 1845-0039). Part 5 L. Reporting of the 2022 OMB Compliance Supplement identified the disbursement date as one of the key items. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) is an electronic report submitted annually to receive funds for the campus-based programs (FWS, FSEOG 34 CFR 673.3; Fiscal Operations Report and Application to Participate Instructions). Part 5 L. Reporting of the 2022 OMB Compliance Supplement identified various line items as key items containing critical information. Condition: 1. Out of 31 samples of disbursements tested, we noted 22 (or 71%) disbursements where the disbursement date per student account ledger did not match the disbursement date reported in the COD system. 2. We noted differences in the key line items reported in the FISAP report and per the underlying records as follows: "See Schedule of Findings and Questioned Costs for the table" Cause: The University lacks adequate review controls to ensure the accuracy of information being reported in the COD system and in the FISAP report. Effect: The University is noncompliant with reporting requirements. Recommendation: The University should implement review controls over reports required to be submitted for the programs under the SFA cluster. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Special Tests and Provisions ? Return of Title IV Funds Questioned Cost: $0 Criteria: 34 CFR 668.20(d) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. 34 CFR 668.22(j) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 45 days after the date of the institution?s determination that the student withdrew. Condition: Of the five (5) samples tested, we noted one (1) sample where the University did not return the funds within the required time frame. Cause: The University?s management is not experienced with handling title IV funds and was not aware that there is a timeline to return funds for non-attendance or withdrawal of students. Effect: The University is noncompliant with the requirements of the special test and provisions on return of Title IV funds. Identification as a repeat finding: 2021-008 Recommendation: The University should improve its controls over the timely determination of whether a student has ceased attendance for purposes of computing a return of Title IV funds. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education Assistance Listing Number and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Cash Management Questioned Cost: $55,915 Criteria: 34 CFR 668.162(d) states that under the heightened cash monitoring payment method, an institution must credit a student's ledger account for the amount of Title IV HEA program funds that the student or parent is eligible to receive, and pay the amount of any credit balance due under ? 668.164(h), before the institution submits a request for funds under the provisions of the advance payment method described in paragraphs (b)(1) and (2) of 34 CFR 668.162, except that the institution's request may not exceed the amount of the disbursements the institution has made to the students included in that request. Condition: Of the 75 samples tested, we noted 29 samples (or 39%) where the University did not credit the student?s ledger account before submitting a request for funds. Further, we noted 3 (or 4%) samples where the University made the disbursement beyond 3 days following the receipt of funds. Cause: The University lacks effective controls to ensure compliance with cash management requirements. Effect: The University is noncompliant with cash management requirements. Known questioned costs exist amounting to $55,915. Identification as a repeat finding: 2021-005 Recommendation: The University?s management should review the requirements of the Uniform Guidance and coordinate with its third-party private financial aid consultant in developing and implementing effective controls over compliance with cash management requirements. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Reporting Questioned Cost: $0 Criteria: Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system (OMB No. 1845-0039). Part 5 L. Reporting of the 2022 OMB Compliance Supplement identified the disbursement date as one of the key items. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) is an electronic report submitted annually to receive funds for the campus-based programs (FWS, FSEOG 34 CFR 673.3; Fiscal Operations Report and Application to Participate Instructions). Part 5 L. Reporting of the 2022 OMB Compliance Supplement identified various line items as key items containing critical information. Condition: 1. Out of 31 samples of disbursements tested, we noted 22 (or 71%) disbursements where the disbursement date per student account ledger did not match the disbursement date reported in the COD system. 2. We noted differences in the key line items reported in the FISAP report and per the underlying records as follows: "See Schedule of Findings and Questioned Costs for the table" Cause: The University lacks adequate review controls to ensure the accuracy of information being reported in the COD system and in the FISAP report. Effect: The University is noncompliant with reporting requirements. Recommendation: The University should implement review controls over reports required to be submitted for the programs under the SFA cluster. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Special Tests and Provisions ? Return of Title IV Funds Questioned Cost: $0 Criteria: 34 CFR 668.20(d) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. 34 CFR 668.22(j) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 45 days after the date of the institution?s determination that the student withdrew. Condition: Of the five (5) samples tested, we noted one (1) sample where the University did not return the funds within the required time frame. Cause: The University?s management is not experienced with handling title IV funds and was not aware that there is a timeline to return funds for non-attendance or withdrawal of students. Effect: The University is noncompliant with the requirements of the special test and provisions on return of Title IV funds. Identification as a repeat finding: 2021-008 Recommendation: The University should improve its controls over the timely determination of whether a student has ceased attendance for purposes of computing a return of Title IV funds. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education Assistance Listing Number and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Cash Management Questioned Cost: $55,915 Criteria: 34 CFR 668.162(d) states that under the heightened cash monitoring payment method, an institution must credit a student's ledger account for the amount of Title IV HEA program funds that the student or parent is eligible to receive, and pay the amount of any credit balance due under ? 668.164(h), before the institution submits a request for funds under the provisions of the advance payment method described in paragraphs (b)(1) and (2) of 34 CFR 668.162, except that the institution's request may not exceed the amount of the disbursements the institution has made to the students included in that request. Condition: Of the 75 samples tested, we noted 29 samples (or 39%) where the University did not credit the student?s ledger account before submitting a request for funds. Further, we noted 3 (or 4%) samples where the University made the disbursement beyond 3 days following the receipt of funds. Cause: The University lacks effective controls to ensure compliance with cash management requirements. Effect: The University is noncompliant with cash management requirements. Known questioned costs exist amounting to $55,915. Identification as a repeat finding: 2021-005 Recommendation: The University?s management should review the requirements of the Uniform Guidance and coordinate with its third-party private financial aid consultant in developing and implementing effective controls over compliance with cash management requirements. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Reporting Questioned Cost: $0 Criteria: Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system (OMB No. 1845-0039). Part 5 L. Reporting of the 2022 OMB Compliance Supplement identified the disbursement date as one of the key items. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) is an electronic report submitted annually to receive funds for the campus-based programs (FWS, FSEOG 34 CFR 673.3; Fiscal Operations Report and Application to Participate Instructions). Part 5 L. Reporting of the 2022 OMB Compliance Supplement identified various line items as key items containing critical information. Condition: 1. Out of 31 samples of disbursements tested, we noted 22 (or 71%) disbursements where the disbursement date per student account ledger did not match the disbursement date reported in the COD system. 2. We noted differences in the key line items reported in the FISAP report and per the underlying records as follows: "See Schedule of Findings and Questioned Costs for the table" Cause: The University lacks adequate review controls to ensure the accuracy of information being reported in the COD system and in the FISAP report. Effect: The University is noncompliant with reporting requirements. Recommendation: The University should implement review controls over reports required to be submitted for the programs under the SFA cluster. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Special Tests and Provisions ? Return of Title IV Funds Questioned Cost: $0 Criteria: 34 CFR 668.20(d) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. 34 CFR 668.22(j) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 45 days after the date of the institution?s determination that the student withdrew. Condition: Of the five (5) samples tested, we noted one (1) sample where the University did not return the funds within the required time frame. Cause: The University?s management is not experienced with handling title IV funds and was not aware that there is a timeline to return funds for non-attendance or withdrawal of students. Effect: The University is noncompliant with the requirements of the special test and provisions on return of Title IV funds. Identification as a repeat finding: 2021-008 Recommendation: The University should improve its controls over the timely determination of whether a student has ceased attendance for purposes of computing a return of Title IV funds. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education Assistance Listing Number and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Cash Management Questioned Cost: $55,915 Criteria: 34 CFR 668.162(d) states that under the heightened cash monitoring payment method, an institution must credit a student's ledger account for the amount of Title IV HEA program funds that the student or parent is eligible to receive, and pay the amount of any credit balance due under ? 668.164(h), before the institution submits a request for funds under the provisions of the advance payment method described in paragraphs (b)(1) and (2) of 34 CFR 668.162, except that the institution's request may not exceed the amount of the disbursements the institution has made to the students included in that request. Condition: Of the 75 samples tested, we noted 29 samples (or 39%) where the University did not credit the student?s ledger account before submitting a request for funds. Further, we noted 3 (or 4%) samples where the University made the disbursement beyond 3 days following the receipt of funds. Cause: The University lacks effective controls to ensure compliance with cash management requirements. Effect: The University is noncompliant with cash management requirements. Known questioned costs exist amounting to $55,915. Identification as a repeat finding: 2021-005 Recommendation: The University?s management should review the requirements of the Uniform Guidance and coordinate with its third-party private financial aid consultant in developing and implementing effective controls over compliance with cash management requirements. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Reporting Questioned Cost: $0 Criteria: Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system (OMB No. 1845-0039). Part 5 L. Reporting of the 2022 OMB Compliance Supplement identified the disbursement date as one of the key items. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) is an electronic report submitted annually to receive funds for the campus-based programs (FWS, FSEOG 34 CFR 673.3; Fiscal Operations Report and Application to Participate Instructions). Part 5 L. Reporting of the 2022 OMB Compliance Supplement identified various line items as key items containing critical information. Condition: 1. Out of 31 samples of disbursements tested, we noted 22 (or 71%) disbursements where the disbursement date per student account ledger did not match the disbursement date reported in the COD system. 2. We noted differences in the key line items reported in the FISAP report and per the underlying records as follows: "See Schedule of Findings and Questioned Costs for the table" Cause: The University lacks adequate review controls to ensure the accuracy of information being reported in the COD system and in the FISAP report. Effect: The University is noncompliant with reporting requirements. Recommendation: The University should implement review controls over reports required to be submitted for the programs under the SFA cluster. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster ? 84.268 Federal Direct Student Loans Award Number: Various Area: Special Tests and Provisions ? Disbursements to or on Behalf of Students Questioned Cost: $0 Criteria: An additional requirement of the Direct Loan program is that institutions must implement a quality assurance system (34 CFR 685.300(b)(9)). Conditions No documentation was provided of the University?s Direct Loan quality assurance system. Cause: The University is not familiar with the requirements of special tests and provisions. Effect: The University is noncompliant with the requirements of the special test and provisions on disbursements to or on behalf of students. Recommendation: The University must implement procedures to improve its knowledge of special tests and provisions required for the federal programs under the SFA cluster. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster ? 84.268 Federal Direct Student Loans Award Number: Various Area: Special Tests and Provisions ? Direct Loan Reconciliation Questioned Cost: $0 Criteria: 34 CFR 685.300(b)(5) requires institutions to reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary (through School Account Statements (SAS) from COD)). Condition: No documentation was provided for monthly reconciliations performed from July to December 2021. Cause: The University only started performing reconciliations in January 2022 with the assistance of its third-party financial aid private consultant. Effect: The University is noncompliant with the requirements of the special test and provisions on direct loan reconciliation. Identification as a repeat finding: 2021-009 Recommendation: The University must implement monitoring controls over the monthly direct loan reconciliation process performed by the third-party financial aid private consultant. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Special Tests and Provisions ? Return of Title IV Funds Questioned Cost: $0 Criteria: 34 CFR 668.20(d) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. 34 CFR 668.22(j) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 45 days after the date of the institution?s determination that the student withdrew. Condition: Of the five (5) samples tested, we noted one (1) sample where the University did not return the funds within the required time frame. Cause: The University?s management is not experienced with handling title IV funds and was not aware that there is a timeline to return funds for non-attendance or withdrawal of students. Effect: The University is noncompliant with the requirements of the special test and provisions on return of Title IV funds. Identification as a repeat finding: 2021-008 Recommendation: The University should improve its controls over the timely determination of whether a student has ceased attendance for purposes of computing a return of Title IV funds. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education Assistance Listing Number and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Cash Management Questioned Cost: $55,915 Criteria: 34 CFR 668.162(d) states that under the heightened cash monitoring payment method, an institution must credit a student's ledger account for the amount of Title IV HEA program funds that the student or parent is eligible to receive, and pay the amount of any credit balance due under ? 668.164(h), before the institution submits a request for funds under the provisions of the advance payment method described in paragraphs (b)(1) and (2) of 34 CFR 668.162, except that the institution's request may not exceed the amount of the disbursements the institution has made to the students included in that request. Condition: Of the 75 samples tested, we noted 29 samples (or 39%) where the University did not credit the student?s ledger account before submitting a request for funds. Further, we noted 3 (or 4%) samples where the University made the disbursement beyond 3 days following the receipt of funds. Cause: The University lacks effective controls to ensure compliance with cash management requirements. Effect: The University is noncompliant with cash management requirements. Known questioned costs exist amounting to $55,915. Identification as a repeat finding: 2021-005 Recommendation: The University?s management should review the requirements of the Uniform Guidance and coordinate with its third-party private financial aid consultant in developing and implementing effective controls over compliance with cash management requirements. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Reporting Questioned Cost: $0 Criteria: Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system (OMB No. 1845-0039). Part 5 L. Reporting of the 2022 OMB Compliance Supplement identified the disbursement date as one of the key items. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) is an electronic report submitted annually to receive funds for the campus-based programs (FWS, FSEOG 34 CFR 673.3; Fiscal Operations Report and Application to Participate Instructions). Part 5 L. Reporting of the 2022 OMB Compliance Supplement identified various line items as key items containing critical information. Condition: 1. Out of 31 samples of disbursements tested, we noted 22 (or 71%) disbursements where the disbursement date per student account ledger did not match the disbursement date reported in the COD system. 2. We noted differences in the key line items reported in the FISAP report and per the underlying records as follows: "See Schedule of Findings and Questioned Costs for the table" Cause: The University lacks adequate review controls to ensure the accuracy of information being reported in the COD system and in the FISAP report. Effect: The University is noncompliant with reporting requirements. Recommendation: The University should implement review controls over reports required to be submitted for the programs under the SFA cluster. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Special Tests and Provisions ? Return of Title IV Funds Questioned Cost: $0 Criteria: 34 CFR 668.20(d) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. 34 CFR 668.22(j) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 45 days after the date of the institution?s determination that the student withdrew. Condition: Of the five (5) samples tested, we noted one (1) sample where the University did not return the funds within the required time frame. Cause: The University?s management is not experienced with handling title IV funds and was not aware that there is a timeline to return funds for non-attendance or withdrawal of students. Effect: The University is noncompliant with the requirements of the special test and provisions on return of Title IV funds. Identification as a repeat finding: 2021-008 Recommendation: The University should improve its controls over the timely determination of whether a student has ceased attendance for purposes of computing a return of Title IV funds. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education Assistance Listing Number and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Cash Management Questioned Cost: $55,915 Criteria: 34 CFR 668.162(d) states that under the heightened cash monitoring payment method, an institution must credit a student's ledger account for the amount of Title IV HEA program funds that the student or parent is eligible to receive, and pay the amount of any credit balance due under ? 668.164(h), before the institution submits a request for funds under the provisions of the advance payment method described in paragraphs (b)(1) and (2) of 34 CFR 668.162, except that the institution's request may not exceed the amount of the disbursements the institution has made to the students included in that request. Condition: Of the 75 samples tested, we noted 29 samples (or 39%) where the University did not credit the student?s ledger account before submitting a request for funds. Further, we noted 3 (or 4%) samples where the University made the disbursement beyond 3 days following the receipt of funds. Cause: The University lacks effective controls to ensure compliance with cash management requirements. Effect: The University is noncompliant with cash management requirements. Known questioned costs exist amounting to $55,915. Identification as a repeat finding: 2021-005 Recommendation: The University?s management should review the requirements of the Uniform Guidance and coordinate with its third-party private financial aid consultant in developing and implementing effective controls over compliance with cash management requirements. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Reporting Questioned Cost: $0 Criteria: Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system (OMB No. 1845-0039). Part 5 L. Reporting of the 2022 OMB Compliance Supplement identified the disbursement date as one of the key items. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) is an electronic report submitted annually to receive funds for the campus-based programs (FWS, FSEOG 34 CFR 673.3; Fiscal Operations Report and Application to Participate Instructions). Part 5 L. Reporting of the 2022 OMB Compliance Supplement identified various line items as key items containing critical information. Condition: 1. Out of 31 samples of disbursements tested, we noted 22 (or 71%) disbursements where the disbursement date per student account ledger did not match the disbursement date reported in the COD system. 2. We noted differences in the key line items reported in the FISAP report and per the underlying records as follows: "See Schedule of Findings and Questioned Costs for the table" Cause: The University lacks adequate review controls to ensure the accuracy of information being reported in the COD system and in the FISAP report. Effect: The University is noncompliant with reporting requirements. Recommendation: The University should implement review controls over reports required to be submitted for the programs under the SFA cluster. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Special Tests and Provisions ? Return of Title IV Funds Questioned Cost: $0 Criteria: 34 CFR 668.20(d) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. 34 CFR 668.22(j) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 45 days after the date of the institution?s determination that the student withdrew. Condition: Of the five (5) samples tested, we noted one (1) sample where the University did not return the funds within the required time frame. Cause: The University?s management is not experienced with handling title IV funds and was not aware that there is a timeline to return funds for non-attendance or withdrawal of students. Effect: The University is noncompliant with the requirements of the special test and provisions on return of Title IV funds. Identification as a repeat finding: 2021-008 Recommendation: The University should improve its controls over the timely determination of whether a student has ceased attendance for purposes of computing a return of Title IV funds. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education Assistance Listing Number and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Cash Management Questioned Cost: $55,915 Criteria: 34 CFR 668.162(d) states that under the heightened cash monitoring payment method, an institution must credit a student's ledger account for the amount of Title IV HEA program funds that the student or parent is eligible to receive, and pay the amount of any credit balance due under ? 668.164(h), before the institution submits a request for funds under the provisions of the advance payment method described in paragraphs (b)(1) and (2) of 34 CFR 668.162, except that the institution's request may not exceed the amount of the disbursements the institution has made to the students included in that request. Condition: Of the 75 samples tested, we noted 29 samples (or 39%) where the University did not credit the student?s ledger account before submitting a request for funds. Further, we noted 3 (or 4%) samples where the University made the disbursement beyond 3 days following the receipt of funds. Cause: The University lacks effective controls to ensure compliance with cash management requirements. Effect: The University is noncompliant with cash management requirements. Known questioned costs exist amounting to $55,915. Identification as a repeat finding: 2021-005 Recommendation: The University?s management should review the requirements of the Uniform Guidance and coordinate with its third-party private financial aid consultant in developing and implementing effective controls over compliance with cash management requirements. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Reporting Questioned Cost: $0 Criteria: Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system (OMB No. 1845-0039). Part 5 L. Reporting of the 2022 OMB Compliance Supplement identified the disbursement date as one of the key items. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) is an electronic report submitted annually to receive funds for the campus-based programs (FWS, FSEOG 34 CFR 673.3; Fiscal Operations Report and Application to Participate Instructions). Part 5 L. Reporting of the 2022 OMB Compliance Supplement identified various line items as key items containing critical information. Condition: 1. Out of 31 samples of disbursements tested, we noted 22 (or 71%) disbursements where the disbursement date per student account ledger did not match the disbursement date reported in the COD system. 2. We noted differences in the key line items reported in the FISAP report and per the underlying records as follows: "See Schedule of Findings and Questioned Costs for the table" Cause: The University lacks adequate review controls to ensure the accuracy of information being reported in the COD system and in the FISAP report. Effect: The University is noncompliant with reporting requirements. Recommendation: The University should implement review controls over reports required to be submitted for the programs under the SFA cluster. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Special Tests and Provisions ? Return of Title IV Funds Questioned Cost: $0 Criteria: 34 CFR 668.20(d) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. 34 CFR 668.22(j) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 45 days after the date of the institution?s determination that the student withdrew. Condition: Of the five (5) samples tested, we noted one (1) sample where the University did not return the funds within the required time frame. Cause: The University?s management is not experienced with handling title IV funds and was not aware that there is a timeline to return funds for non-attendance or withdrawal of students. Effect: The University is noncompliant with the requirements of the special test and provisions on return of Title IV funds. Identification as a repeat finding: 2021-008 Recommendation: The University should improve its controls over the timely determination of whether a student has ceased attendance for purposes of computing a return of Title IV funds. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education Assistance Listing Number and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Cash Management Questioned Cost: $55,915 Criteria: 34 CFR 668.162(d) states that under the heightened cash monitoring payment method, an institution must credit a student's ledger account for the amount of Title IV HEA program funds that the student or parent is eligible to receive, and pay the amount of any credit balance due under ? 668.164(h), before the institution submits a request for funds under the provisions of the advance payment method described in paragraphs (b)(1) and (2) of 34 CFR 668.162, except that the institution's request may not exceed the amount of the disbursements the institution has made to the students included in that request. Condition: Of the 75 samples tested, we noted 29 samples (or 39%) where the University did not credit the student?s ledger account before submitting a request for funds. Further, we noted 3 (or 4%) samples where the University made the disbursement beyond 3 days following the receipt of funds. Cause: The University lacks effective controls to ensure compliance with cash management requirements. Effect: The University is noncompliant with cash management requirements. Known questioned costs exist amounting to $55,915. Identification as a repeat finding: 2021-005 Recommendation: The University?s management should review the requirements of the Uniform Guidance and coordinate with its third-party private financial aid consultant in developing and implementing effective controls over compliance with cash management requirements. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Reporting Questioned Cost: $0 Criteria: Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system (OMB No. 1845-0039). Part 5 L. Reporting of the 2022 OMB Compliance Supplement identified the disbursement date as one of the key items. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) is an electronic report submitted annually to receive funds for the campus-based programs (FWS, FSEOG 34 CFR 673.3; Fiscal Operations Report and Application to Participate Instructions). Part 5 L. Reporting of the 2022 OMB Compliance Supplement identified various line items as key items containing critical information. Condition: 1. Out of 31 samples of disbursements tested, we noted 22 (or 71%) disbursements where the disbursement date per student account ledger did not match the disbursement date reported in the COD system. 2. We noted differences in the key line items reported in the FISAP report and per the underlying records as follows: "See Schedule of Findings and Questioned Costs for the table" Cause: The University lacks adequate review controls to ensure the accuracy of information being reported in the COD system and in the FISAP report. Effect: The University is noncompliant with reporting requirements. Recommendation: The University should implement review controls over reports required to be submitted for the programs under the SFA cluster. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster ? 84.268 Federal Direct Student Loans Award Number: Various Area: Special Tests and Provisions ? Disbursements to or on Behalf of Students Questioned Cost: $0 Criteria: An additional requirement of the Direct Loan program is that institutions must implement a quality assurance system (34 CFR 685.300(b)(9)). Conditions No documentation was provided of the University?s Direct Loan quality assurance system. Cause: The University is not familiar with the requirements of special tests and provisions. Effect: The University is noncompliant with the requirements of the special test and provisions on disbursements to or on behalf of students. Recommendation: The University must implement procedures to improve its knowledge of special tests and provisions required for the federal programs under the SFA cluster. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster ? 84.268 Federal Direct Student Loans Award Number: Various Area: Special Tests and Provisions ? Direct Loan Reconciliation Questioned Cost: $0 Criteria: 34 CFR 685.300(b)(5) requires institutions to reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary (through School Account Statements (SAS) from COD)). Condition: No documentation was provided for monthly reconciliations performed from July to December 2021. Cause: The University only started performing reconciliations in January 2022 with the assistance of its third-party financial aid private consultant. Effect: The University is noncompliant with the requirements of the special test and provisions on direct loan reconciliation. Identification as a repeat finding: 2021-009 Recommendation: The University must implement monitoring controls over the monthly direct loan reconciliation process performed by the third-party financial aid private consultant. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Special Tests and Provisions ? Return of Title IV Funds Questioned Cost: $0 Criteria: 34 CFR 668.20(d) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. 34 CFR 668.22(j) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 45 days after the date of the institution?s determination that the student withdrew. Condition: Of the five (5) samples tested, we noted one (1) sample where the University did not return the funds within the required time frame. Cause: The University?s management is not experienced with handling title IV funds and was not aware that there is a timeline to return funds for non-attendance or withdrawal of students. Effect: The University is noncompliant with the requirements of the special test and provisions on return of Title IV funds. Identification as a repeat finding: 2021-008 Recommendation: The University should improve its controls over the timely determination of whether a student has ceased attendance for purposes of computing a return of Title IV funds. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.