Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program
Federal Award Identification Number and Year - June 1, 2023 to May 31, 2024
Pass through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2020-003, 2021-003, 2022-002, 2023-002
Criteria - Schools are required to report enrollment information under the Direct Loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV Student Financial Assistance programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. 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.
Condition - Our audit procedures identified instances of untimely reporting of enrollment information to NSLDS.
Questioned Costs - None
If Questioned Costs are not Determinable, Description of Why Known Questioned Costs were Undetermined or Otherwise could not be Reported - Finding relates to the timeliness of enrollment reporting, which does not impact award amounts.
Identification of How Questioned Costs Were Computed - N/A
Context - During our testing of a sample of four students, we noted the student enrollment was not reported within the required 60 day time period for two students.
Cause and Effect - The School has neither a process nor controls in place to ensure that campus level data and program level student enrollment information is reported to NSLDS in a timely manner.
Untimely reporting of student enrollment data to NSLDS results in noncompliance with federal regulations and untimely data listed within NSLDS. Student information within NSLDS is used to determine award packaging for students attending multiple institutions and repayment periods on direct student loans; stale data within NSLDS could lead to improper award packaging and repayment period determinations.
Recommendation - We recommend the School implement a control to ensure all campus level and program level student enrollment information is reported to NSLDS timely in accordance with the federally required timelines.
Views of Responsible Officials and Corrective Action Plan - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. The School has also ensured that this third party processor is properly coordinated with the registrar’s office to meet federal requirements for NSLDS enrollment reporting.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, 84.038, 84.268; U.S. Department of Education; Student Financial Assistance Cluster
Federal Award Identification Number and Year - June 1, 2023 to May 31, 2024
Pass through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2021-006, 2022-004, 2023-004
Criteria - Institutions of higher education are required to submit a Fiscal Operations Report and Application to Participate (FISAP) to the U.S. Department of Education. This electronic report is submitted annually to receive funds for the campus based programs. The School uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year.
Condition - The School submitted a FISAP to the U.S. Department of Education that reported inaccurate information in several data fields within the report. In addition, there was no evidence that an individual other than the preparer reviewed the report.
Questioned Costs - None
If Questioned Costs are not Determinable, Description of Why Known Questioned Costs were Undetermined or Otherwise could not be Reported - Finding relates to inaccurate information included in the FISAP, which does not impact award amounts.
Identification of How Questioned Costs Were Computed - N/A
Context - During our testing, we noted inaccurate information in data field Part II, Section D (Information for Enrollment), Line 7b: The School reported 150 graduates enrolled for fiscal year 2022 2023. This figure did not agree to supporting documentation, and management determined that the number reported was based on the unduplicated graduate count for fall 2022. Management noted that the number that should have been reported for the 2022 2023 school year was 209.
Management also noted that there was not a formal and documented review process of the FISAP report by someone other than the preparer.
Cause and Effect - The School did not have a control in place to ensure that accurate information was submitted to the U.S. Department of Education in the FISAP report.
Submission of inaccurate information in the FISAP report may result in noncompliance with federal regulations and inaccurate awarding of federal student financial assistance amounts in subsequent fiscal years.
Recommendation - We recommend the School implement a reconciliation and review control where an individual with sufficient student financial assistance and financial understanding reviews the FISAP report to underlying institutional information to ensure accurate information is submitted with the FISAP report. Evidence of such a review and documentation supporting information reported in the FISAP should be documented and maintained.
Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. Preparation and submission of the FISAP will be completed with coordination between the VP of business and the third party processor. This includes a quality review process for accuracy.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, 84.038, 84.268; U.S. Department of Education; Student Financial Assistance Cluster
Federal Award Identification Number and Year - June 1, 2023 to May 31, 2024
Pass through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2021-006, 2022-004, 2023-004
Criteria - Institutions of higher education are required to submit a Fiscal Operations Report and Application to Participate (FISAP) to the U.S. Department of Education. This electronic report is submitted annually to receive funds for the campus based programs. The School uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year.
Condition - The School submitted a FISAP to the U.S. Department of Education that reported inaccurate information in several data fields within the report. In addition, there was no evidence that an individual other than the preparer reviewed the report.
Questioned Costs - None
If Questioned Costs are not Determinable, Description of Why Known Questioned Costs were Undetermined or Otherwise could not be Reported - Finding relates to inaccurate information included in the FISAP, which does not impact award amounts.
Identification of How Questioned Costs Were Computed - N/A
Context - During our testing, we noted inaccurate information in data field Part II, Section D (Information for Enrollment), Line 7b: The School reported 150 graduates enrolled for fiscal year 2022 2023. This figure did not agree to supporting documentation, and management determined that the number reported was based on the unduplicated graduate count for fall 2022. Management noted that the number that should have been reported for the 2022 2023 school year was 209.
Management also noted that there was not a formal and documented review process of the FISAP report by someone other than the preparer.
Cause and Effect - The School did not have a control in place to ensure that accurate information was submitted to the U.S. Department of Education in the FISAP report.
Submission of inaccurate information in the FISAP report may result in noncompliance with federal regulations and inaccurate awarding of federal student financial assistance amounts in subsequent fiscal years.
Recommendation - We recommend the School implement a reconciliation and review control where an individual with sufficient student financial assistance and financial understanding reviews the FISAP report to underlying institutional information to ensure accurate information is submitted with the FISAP report. Evidence of such a review and documentation supporting information reported in the FISAP should be documented and maintained.
Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. Preparation and submission of the FISAP will be completed with coordination between the VP of business and the third party processor. This includes a quality review process for accuracy.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, 84.038, 84.268; U.S. Department of Education; Student Financial Assistance Cluster
Federal Award Identification Number and Year - June 1, 2023 to May 31, 2024
Pass through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2021-006, 2022-004, 2023-004
Criteria - Institutions of higher education are required to submit a Fiscal Operations Report and Application to Participate (FISAP) to the U.S. Department of Education. This electronic report is submitted annually to receive funds for the campus based programs. The School uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year.
Condition - The School submitted a FISAP to the U.S. Department of Education that reported inaccurate information in several data fields within the report. In addition, there was no evidence that an individual other than the preparer reviewed the report.
Questioned Costs - None
If Questioned Costs are not Determinable, Description of Why Known Questioned Costs were Undetermined or Otherwise could not be Reported - Finding relates to inaccurate information included in the FISAP, which does not impact award amounts.
Identification of How Questioned Costs Were Computed - N/A
Context - During our testing, we noted inaccurate information in data field Part II, Section D (Information for Enrollment), Line 7b: The School reported 150 graduates enrolled for fiscal year 2022 2023. This figure did not agree to supporting documentation, and management determined that the number reported was based on the unduplicated graduate count for fall 2022. Management noted that the number that should have been reported for the 2022 2023 school year was 209.
Management also noted that there was not a formal and documented review process of the FISAP report by someone other than the preparer.
Cause and Effect - The School did not have a control in place to ensure that accurate information was submitted to the U.S. Department of Education in the FISAP report.
Submission of inaccurate information in the FISAP report may result in noncompliance with federal regulations and inaccurate awarding of federal student financial assistance amounts in subsequent fiscal years.
Recommendation - We recommend the School implement a reconciliation and review control where an individual with sufficient student financial assistance and financial understanding reviews the FISAP report to underlying institutional information to ensure accurate information is submitted with the FISAP report. Evidence of such a review and documentation supporting information reported in the FISAP should be documented and maintained.
Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. Preparation and submission of the FISAP will be completed with coordination between the VP of business and the third party processor. This includes a quality review process for accuracy.
Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program
Federal Award Identification Number and Year - June 1, 2023 to May 31, 2024
Pass through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2021-011, 2022-007, 2023-007
Criteria - In accordance with 34 CFR 685.300(b)(9) and electronic announcement November 13, 2013, Direct Loan Quality Assurance Requirement Reminder, institutions of higher education are requested to document a Direct Loan quality assurance program.
Condition - The School does not have a documented Direct Loan quality assurance program.
Questioned Costs - None
If Questioned Costs are not Determinable, Description of Why Known Questioned Costs were Undetermined or Otherwise could not be Reported - Finding relates to a policy not in place, which would not impact award amounts.
Identification of How Questioned Costs Were Computed - N/A
Context - During our testing, management stated that the School does not have a documented Direct Loan quality assurance program.
Cause and Effect - The School does not have a process in place to ensure that its Direct Loan quality assurance efforts are documented in accordance with federal regulations.
The lack of a documented Direct Loan quality assurance program for the School results in noncompliance with federal regulations.
Recommendation - We recommend the School establish the required Direct Loan quality assurance program and that contemporaneous evidence of consistent adherence to such a program be maintained.
Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. The School will coordinate with this third party processor to ensure that there is a documented quality assurance program that is regularly exercised for compliance purposes. All documentation will be maintained.
Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program
Federal Award Identification Number and Year - June 1, 2023 to May 31, 2024
Pass through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2020-003, 2021-003, 2022-002, 2023-002
Criteria - Schools are required to report enrollment information under the Direct Loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV Student Financial Assistance programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. 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.
Condition - Our audit procedures identified instances of untimely reporting of enrollment information to NSLDS.
Questioned Costs - None
If Questioned Costs are not Determinable, Description of Why Known Questioned Costs were Undetermined or Otherwise could not be Reported - Finding relates to the timeliness of enrollment reporting, which does not impact award amounts.
Identification of How Questioned Costs Were Computed - N/A
Context - During our testing of a sample of four students, we noted the student enrollment was not reported within the required 60 day time period for two students.
Cause and Effect - The School has neither a process nor controls in place to ensure that campus level data and program level student enrollment information is reported to NSLDS in a timely manner.
Untimely reporting of student enrollment data to NSLDS results in noncompliance with federal regulations and untimely data listed within NSLDS. Student information within NSLDS is used to determine award packaging for students attending multiple institutions and repayment periods on direct student loans; stale data within NSLDS could lead to improper award packaging and repayment period determinations.
Recommendation - We recommend the School implement a control to ensure all campus level and program level student enrollment information is reported to NSLDS timely in accordance with the federally required timelines.
Views of Responsible Officials and Corrective Action Plan - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. The School has also ensured that this third party processor is properly coordinated with the registrar’s office to meet federal requirements for NSLDS enrollment reporting.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, 84.038, 84.268; U.S. Department of Education; Student Financial Assistance Cluster
Federal Award Identification Number and Year - June 1, 2023 to May 31, 2024
Pass through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2021-006, 2022-004, 2023-004
Criteria - Institutions of higher education are required to submit a Fiscal Operations Report and Application to Participate (FISAP) to the U.S. Department of Education. This electronic report is submitted annually to receive funds for the campus based programs. The School uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year.
Condition - The School submitted a FISAP to the U.S. Department of Education that reported inaccurate information in several data fields within the report. In addition, there was no evidence that an individual other than the preparer reviewed the report.
Questioned Costs - None
If Questioned Costs are not Determinable, Description of Why Known Questioned Costs were Undetermined or Otherwise could not be Reported - Finding relates to inaccurate information included in the FISAP, which does not impact award amounts.
Identification of How Questioned Costs Were Computed - N/A
Context - During our testing, we noted inaccurate information in data field Part II, Section D (Information for Enrollment), Line 7b: The School reported 150 graduates enrolled for fiscal year 2022 2023. This figure did not agree to supporting documentation, and management determined that the number reported was based on the unduplicated graduate count for fall 2022. Management noted that the number that should have been reported for the 2022 2023 school year was 209.
Management also noted that there was not a formal and documented review process of the FISAP report by someone other than the preparer.
Cause and Effect - The School did not have a control in place to ensure that accurate information was submitted to the U.S. Department of Education in the FISAP report.
Submission of inaccurate information in the FISAP report may result in noncompliance with federal regulations and inaccurate awarding of federal student financial assistance amounts in subsequent fiscal years.
Recommendation - We recommend the School implement a reconciliation and review control where an individual with sufficient student financial assistance and financial understanding reviews the FISAP report to underlying institutional information to ensure accurate information is submitted with the FISAP report. Evidence of such a review and documentation supporting information reported in the FISAP should be documented and maintained.
Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. Preparation and submission of the FISAP will be completed with coordination between the VP of business and the third party processor. This includes a quality review process for accuracy.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, 84.038, 84.268; U.S. Department of Education; Student Financial Assistance Cluster
Federal Award Identification Number and Year - June 1, 2023 to May 31, 2024
Pass through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2021-006, 2022-004, 2023-004
Criteria - Institutions of higher education are required to submit a Fiscal Operations Report and Application to Participate (FISAP) to the U.S. Department of Education. This electronic report is submitted annually to receive funds for the campus based programs. The School uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year.
Condition - The School submitted a FISAP to the U.S. Department of Education that reported inaccurate information in several data fields within the report. In addition, there was no evidence that an individual other than the preparer reviewed the report.
Questioned Costs - None
If Questioned Costs are not Determinable, Description of Why Known Questioned Costs were Undetermined or Otherwise could not be Reported - Finding relates to inaccurate information included in the FISAP, which does not impact award amounts.
Identification of How Questioned Costs Were Computed - N/A
Context - During our testing, we noted inaccurate information in data field Part II, Section D (Information for Enrollment), Line 7b: The School reported 150 graduates enrolled for fiscal year 2022 2023. This figure did not agree to supporting documentation, and management determined that the number reported was based on the unduplicated graduate count for fall 2022. Management noted that the number that should have been reported for the 2022 2023 school year was 209.
Management also noted that there was not a formal and documented review process of the FISAP report by someone other than the preparer.
Cause and Effect - The School did not have a control in place to ensure that accurate information was submitted to the U.S. Department of Education in the FISAP report.
Submission of inaccurate information in the FISAP report may result in noncompliance with federal regulations and inaccurate awarding of federal student financial assistance amounts in subsequent fiscal years.
Recommendation - We recommend the School implement a reconciliation and review control where an individual with sufficient student financial assistance and financial understanding reviews the FISAP report to underlying institutional information to ensure accurate information is submitted with the FISAP report. Evidence of such a review and documentation supporting information reported in the FISAP should be documented and maintained.
Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. Preparation and submission of the FISAP will be completed with coordination between the VP of business and the third party processor. This includes a quality review process for accuracy.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, 84.038, 84.268; U.S. Department of Education; Student Financial Assistance Cluster
Federal Award Identification Number and Year - June 1, 2023 to May 31, 2024
Pass through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2021-006, 2022-004, 2023-004
Criteria - Institutions of higher education are required to submit a Fiscal Operations Report and Application to Participate (FISAP) to the U.S. Department of Education. This electronic report is submitted annually to receive funds for the campus based programs. The School uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year.
Condition - The School submitted a FISAP to the U.S. Department of Education that reported inaccurate information in several data fields within the report. In addition, there was no evidence that an individual other than the preparer reviewed the report.
Questioned Costs - None
If Questioned Costs are not Determinable, Description of Why Known Questioned Costs were Undetermined or Otherwise could not be Reported - Finding relates to inaccurate information included in the FISAP, which does not impact award amounts.
Identification of How Questioned Costs Were Computed - N/A
Context - During our testing, we noted inaccurate information in data field Part II, Section D (Information for Enrollment), Line 7b: The School reported 150 graduates enrolled for fiscal year 2022 2023. This figure did not agree to supporting documentation, and management determined that the number reported was based on the unduplicated graduate count for fall 2022. Management noted that the number that should have been reported for the 2022 2023 school year was 209.
Management also noted that there was not a formal and documented review process of the FISAP report by someone other than the preparer.
Cause and Effect - The School did not have a control in place to ensure that accurate information was submitted to the U.S. Department of Education in the FISAP report.
Submission of inaccurate information in the FISAP report may result in noncompliance with federal regulations and inaccurate awarding of federal student financial assistance amounts in subsequent fiscal years.
Recommendation - We recommend the School implement a reconciliation and review control where an individual with sufficient student financial assistance and financial understanding reviews the FISAP report to underlying institutional information to ensure accurate information is submitted with the FISAP report. Evidence of such a review and documentation supporting information reported in the FISAP should be documented and maintained.
Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. Preparation and submission of the FISAP will be completed with coordination between the VP of business and the third party processor. This includes a quality review process for accuracy.
Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program
Federal Award Identification Number and Year - June 1, 2023 to May 31, 2024
Pass through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2021-011, 2022-007, 2023-007
Criteria - In accordance with 34 CFR 685.300(b)(9) and electronic announcement November 13, 2013, Direct Loan Quality Assurance Requirement Reminder, institutions of higher education are requested to document a Direct Loan quality assurance program.
Condition - The School does not have a documented Direct Loan quality assurance program.
Questioned Costs - None
If Questioned Costs are not Determinable, Description of Why Known Questioned Costs were Undetermined or Otherwise could not be Reported - Finding relates to a policy not in place, which would not impact award amounts.
Identification of How Questioned Costs Were Computed - N/A
Context - During our testing, management stated that the School does not have a documented Direct Loan quality assurance program.
Cause and Effect - The School does not have a process in place to ensure that its Direct Loan quality assurance efforts are documented in accordance with federal regulations.
The lack of a documented Direct Loan quality assurance program for the School results in noncompliance with federal regulations.
Recommendation - We recommend the School establish the required Direct Loan quality assurance program and that contemporaneous evidence of consistent adherence to such a program be maintained.
Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. The School will coordinate with this third party processor to ensure that there is a documented quality assurance program that is regularly exercised for compliance purposes. All documentation will be maintained.