Audit 328012

FY End
2024-06-30
Total Expended
$10.28M
Findings
4
Programs
2
Year: 2024 Accepted: 2024-11-12

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
505361 2024-001 Significant Deficiency - N
505362 2024-001 Significant Deficiency - N
1081803 2024-001 Significant Deficiency - N
1081804 2024-001 Significant Deficiency - N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $10.13M Yes 1
84.033 Federal Work-Study Program $150,668 Yes 1

Contacts

Name Title Type
C2DPJYN5DHM3 Kaye Castro Auditee
2396875343 Michelle Fowler, CPA Auditor
No contacts on file

Notes to SEFA

Title: FEDERAL DIRECT STUDENT LOANS PROGRAM Accounting Policies: The accompanying schedule of expenditures of federal awards (the “Schedule”) includes the federal grant activity of Ave Maria School of Law and Ave Maria School of Law Foundation (a Florida not-for-profit corporation) (the "Organization") under programs of the federal government for the year ended June 30, 2024. 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). Because the Schedule presents only a selected portion of the operations of the Organization, it is not intended to and does not present the consolidated financial position, changes in net assets or cash flows of the Organization. Expenditures reported on the Schedule are reported on the accrual basis of accounting, which is described in Note 1 to the Organization’s consolidated financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance or other applicable guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: For purposes of charging indirect costs to federal awards, the Organization has not elected to use the 10 percent de minimis cost rate as permitted by §200.414 of the Uniform Guidance. The Organization participates under the Federal Direct Student Loans program. The Organization acts as the intermediary for students obtaining Federal Direct Student Loans (Assistance Listing No. 84.268) from the U.S. Department of Education (the “Department”). The Department is responsible for billings and collections of the loans. The Organization assists the Department by processing the applications and disbursing the funds from the Department to the students. Loans made during the year are included in the federal expenditures presented in the Schedule.

Finding Details

2024-001 Special Tests and Provisions - Enrollment Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.033 and 84.268; Award Numbers P033A238732 and P268K246780. Criteria. Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Condition. We noted that twelve students out of a testing population of twelve did not have the correct program begin date reported. Cause. This condition was caused by a prior policy, which recorded the program begin date as a default date that was entered into the system, rather than the term that the student began their program. Effect. As a result of this condition, the Organization was exposed to an increased risk that incorrect information would be reported to NSLDS. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the Organization enhance its policies and procedures regarding enrollment reporting to ensure that reporting is completed accurately. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-001 Special Tests and Provisions - Enrollment Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.033 and 84.268; Award Numbers P033A238732 and P268K246780. Criteria. Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Condition. We noted that twelve students out of a testing population of twelve did not have the correct program begin date reported. Cause. This condition was caused by a prior policy, which recorded the program begin date as a default date that was entered into the system, rather than the term that the student began their program. Effect. As a result of this condition, the Organization was exposed to an increased risk that incorrect information would be reported to NSLDS. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the Organization enhance its policies and procedures regarding enrollment reporting to ensure that reporting is completed accurately. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-001 Special Tests and Provisions - Enrollment Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.033 and 84.268; Award Numbers P033A238732 and P268K246780. Criteria. Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Condition. We noted that twelve students out of a testing population of twelve did not have the correct program begin date reported. Cause. This condition was caused by a prior policy, which recorded the program begin date as a default date that was entered into the system, rather than the term that the student began their program. Effect. As a result of this condition, the Organization was exposed to an increased risk that incorrect information would be reported to NSLDS. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the Organization enhance its policies and procedures regarding enrollment reporting to ensure that reporting is completed accurately. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-001 Special Tests and Provisions - Enrollment Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.033 and 84.268; Award Numbers P033A238732 and P268K246780. Criteria. Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Condition. We noted that twelve students out of a testing population of twelve did not have the correct program begin date reported. Cause. This condition was caused by a prior policy, which recorded the program begin date as a default date that was entered into the system, rather than the term that the student began their program. Effect. As a result of this condition, the Organization was exposed to an increased risk that incorrect information would be reported to NSLDS. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the Organization enhance its policies and procedures regarding enrollment reporting to ensure that reporting is completed accurately. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.