Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans AL #?s: 84.268 Award year: 2022 Criteria According to 34 CFR 690.83(b): (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student?s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student?s Payment Data reporting to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 83, Number 233): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV, Higher Education Act (?HEA?) program funds are disbursed on the date that the institution: (a) Credits those funds to a student?s account in the institution?s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the Academy to report Direct Student Loan disbursements made to students to the Federal Government?s Common Origination and Disbursement System (?COD?) within 15 days of the funds being disbursed to the student. During our testing, we noted 23 students, out of a sample of 25 Direct Student Loan recipients, were not reported within the required timeframe. Cause The Academy has policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days; however, in this case the procedures were not completed properly. Effect The Academy did not report Direct Student Loan disbursements to COD within the required time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 25 students selected for testing, 23 students, or 92% of our sample, was determined to be reported late to the COD. Identification as a Repeat Finding, if applicable See finding 2021-001 included in the summary schedule of prior year findings. Recommendation We recommend that management of the Academy review, and if necessary, update the policies and procedures to ensure all Direct Student Loan funds are reported within the required timeframe. View of Responsible Officials The Academy agrees with the finding.
Finding number: 2022-002 Federal agency: U.S. Department of Education Programs: Higher Education Relief Fund ? Institutional Portion AL #?s: 84.425F Award year: 2022 Criteria Section 18004(a)(1) of the Coronavirus Aid, Relief, and Economic Security Act required that institutions submit an Annual Report to the Department of Education that details the institution's annual expenditures accurately and that the expenditures reconcile with institution's underlying records. Condition During our testing, we noted that the Annual Report submitted by the Academy was not accurate and did not reconcile with the Academy's underlying records. The Academy reported that institutional funds were used for providing reimbursements for tuition, housing, room and board, or other fee refunds, while these funds were actually used to replace lost revenue from academic sources. Effect The Academy's Annual Report submitted to the Department of Education was not accurate. Questioned Costs Not applicable Recommendation The Academy should create procedures to ensure the Academy is in compliance with the program's reporting requirements. View of Responsible Officials The Academy agrees with the finding.
Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans AL #?s: 84.268 Award year: 2022 Criteria According to 34 CFR 690.83(b): (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student?s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student?s Payment Data reporting to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 83, Number 233): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV, Higher Education Act (?HEA?) program funds are disbursed on the date that the institution: (a) Credits those funds to a student?s account in the institution?s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the Academy to report Direct Student Loan disbursements made to students to the Federal Government?s Common Origination and Disbursement System (?COD?) within 15 days of the funds being disbursed to the student. During our testing, we noted 23 students, out of a sample of 25 Direct Student Loan recipients, were not reported within the required timeframe. Cause The Academy has policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days; however, in this case the procedures were not completed properly. Effect The Academy did not report Direct Student Loan disbursements to COD within the required time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 25 students selected for testing, 23 students, or 92% of our sample, was determined to be reported late to the COD. Identification as a Repeat Finding, if applicable See finding 2021-001 included in the summary schedule of prior year findings. Recommendation We recommend that management of the Academy review, and if necessary, update the policies and procedures to ensure all Direct Student Loan funds are reported within the required timeframe. View of Responsible Officials The Academy agrees with the finding.
Finding number: 2022-002 Federal agency: U.S. Department of Education Programs: Higher Education Relief Fund ? Institutional Portion AL #?s: 84.425F Award year: 2022 Criteria Section 18004(a)(1) of the Coronavirus Aid, Relief, and Economic Security Act required that institutions submit an Annual Report to the Department of Education that details the institution's annual expenditures accurately and that the expenditures reconcile with institution's underlying records. Condition During our testing, we noted that the Annual Report submitted by the Academy was not accurate and did not reconcile with the Academy's underlying records. The Academy reported that institutional funds were used for providing reimbursements for tuition, housing, room and board, or other fee refunds, while these funds were actually used to replace lost revenue from academic sources. Effect The Academy's Annual Report submitted to the Department of Education was not accurate. Questioned Costs Not applicable Recommendation The Academy should create procedures to ensure the Academy is in compliance with the program's reporting requirements. View of Responsible Officials The Academy agrees with the finding.