Audit 339558

Program: Federal Direct Student Loans CFDA 84.268 Criteria: Per 34 Code of Federal Regulations ("CFR") 685.023 Loan Limits, the aggregate unpaid principal amount of all Direct Subsidized Loans made to a student may not exceed $23,000 for a student who has not successfully completed a program of study at the undergraduate level. Condition: The College's internal controls surrounding the disbursement of Federal Direct Student Loans to students were not adequate to maintain compliance with Title IV regulations. Repeat Finding from Prior Year: No Questioned Cost: None Context: Out of the 40 students tested, one student's aggregate unpaid principal amount of all Direct Subsidized Loans exceeded the $23,000 loan limit. Effect: Cleveland Institute of Art did not meet the requirement of ensuring that the student's aggregate borrowing of Direct Subsidized Loans was within the borrowing limitations established per CFR 685.023 Loan Limits. Cause: The overpayment identified is due to a transfer student's Direct Subsidized Loan history not being adequately reviewed. Recommendation: Implement a system of internal controls to closely monitor the awarding of Direct Subsidized Loans to transfer students and fourth year students whose aggregate borrowings are close to limit. Management Response: Management acknowledges that there was an error in the amount of Direct Subsidized Loan awarded to the student. The College reviewed all aggregate Direct Subsidized Loan awards for 2023-2024 and noted this was an isolated incident. The College is also strengthening its internal controls around monitoring ISIR comment codes 255, 256, 258, 260 and 261 on a continual basis during packaging season to look for any potential over awards and to pay close attention to transfer students and fourth year student loan limits, and to monitor subsequent ISIR transactions for NSLDS post-screenings.

Program: Federal Direct Student Loans CFDA 84.268 Criteria: Per 34 Code of Federal Regulations ("CFR") 685.023 Loan Limits, the aggregate unpaid principal amount of all Direct Subsidized Loans made to a student may not exceed $23,000 for a student who has not successfully completed a program of study at the undergraduate level. Condition: The College's internal controls surrounding the disbursement of Federal Direct Student Loans to students were not adequate to maintain compliance with Title IV regulations. Repeat Finding from Prior Year: No Questioned Cost: None Context: Out of the 40 students tested, one student's aggregate unpaid principal amount of all Direct Subsidized Loans exceeded the $23,000 loan limit. Effect: Cleveland Institute of Art did not meet the requirement of ensuring that the student's aggregate borrowing of Direct Subsidized Loans was within the borrowing limitations established per CFR 685.023 Loan Limits. Cause: The overpayment identified is due to a transfer student's Direct Subsidized Loan history not being adequately reviewed. Recommendation: Implement a system of internal controls to closely monitor the awarding of Direct Subsidized Loans to transfer students and fourth year students whose aggregate borrowings are close to limit. Management Response: Management acknowledges that there was an error in the amount of Direct Subsidized Loan awarded to the student. The College reviewed all aggregate Direct Subsidized Loan awards for 2023-2024 and noted this was an isolated incident. The College is also strengthening its internal controls around monitoring ISIR comment codes 255, 256, 258, 260 and 261 on a continual basis during packaging season to look for any potential over awards and to pay close attention to transfer students and fourth year student loan limits, and to monitor subsequent ISIR transactions for NSLDS post-screenings.