Assistance Listing Number, Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness Repeat Finding - Yes - 2021-005 Criteria - The Seminary is required to maintain documentation of the initiation and approval by the designated individual at the Seminary that the cash drawdowns are certified in accordance with 2 CFR 200.415. Condition - Of the two drawdowns selected in our testing, the Seminary did not retain documentation to support one of the samples that the drawdown request was initiated, reviewed, and approved by the appropriate individuals. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - For all draws in the fiscal year that occurred prior to January 2022, the Seminary was relying solely on email communication between the student financial aid director and the bursar to support the requirements. The documentation does not meet the requirements to support that the Seminary is in compliance with the required regulations. Cause and Effect - The lack of maintaining records of the review and approval of the cash management process could lead to a lack of segregation of duties, as well as potential misstatement of funds, including funds being drawn on the incorrect grant, funds used for an unallowable cost, or funds recorded at an incorrect amount. Recommendation - We recommend the Seminary implement procedures and controls to ensure that drawdown documentation is maintained supporting that independent review was performed for each drawdown, including supporting documentation of approval of the cash drawdown. Views of Responsible Officials and Planned Corrective Actions - The financial aid director is implementing a procedure that will involve an email with supporting documentation for the drawdown requests sent to the CFO or VP of enrollment for review. The individual will sign a statement indicating the information has been reviewed and is accurate and the funds have been approved for drawdown. That email will then be forwarded to the controller to draw down the funds in G5. These requests/approvals will be documented in our internal office drawdown request folder.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness Repeat Finding - Yes - 2021-007 Criteria - The Seminary has 45 days from the date the college determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds. Withdrawal dates are defined as the time when the student officially withdrawals, or expresses notification to withdrawal, or if the student does not officially withdraw, the date the Seminary determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)). Condition - The Seminary did not have controls in place to identify and document the students who have withdrawn and the applicability of performing a return of Title IV funds. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The Seminary did not have a control in place to maintain documentation of the student financial aid department's review and consideration on the applicability of a return to title IV calculation. Subsequent to the fiscal year, the Seminary reviewed the original data files produced throughout the year by the registrar and updated documentation to support compliance. This assessment resulted in no students identified during testing that required a calculation to be performed. Cause and Effect - The Seminary did not have proper controls in place to identity and document students who have withdrawn from the Seminary. The lack of documentation around students who withdrew officially or unofficially led to the inability to support the compliance with the applicable code of federal regulations in a timely manner. Recommendation - The Seminary should implement a procedure that documents the Seminary's review of the student's individual facts and circumstances including, but not limited to, documenting the date of disbursement, the date of withdrawal, and the date of determination by the institution, whether the student is deemed an official or unofficial withdrawal. Views of Responsible Officials and Planned Corrective Actions - The financial aid director has created a spreadsheet to document detailed student information for withdrawals to include withdrawal date, whether federal funds were received, date R2T4 was calculated, if/how much unearned aid was returned, date processed, and any helpful notes for each student. The registrar will continue to email financial aid with any withdrawal details.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.038, U.S. Department of Education, Federal Perkins Loans Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - In accordance with CFR 676.19 (b)(2) and (3), an institution should establish and maintain fiscal records that are reconciled at least monthly and each year the institution shall submit a fiscal operations report plus other information the secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the secretary. Condition - The Seminary did not have the appropriate procedures and controls in place to file an accurate and timely Fiscal Operations Report and Application to Participate (FISAP). Questioned Costs - N/A Context - The Seminary's FISAP was filed after the due date of September 30, 2022. In addition, the Seminary reported inaccurate information, including inaccurate Perkins loan awards, the number of students to whom federal work study was awarded, and the amount of compensation paid with federal funds. During our testing, the reports used to complete the FISAP included a student that was not eligible for federal work study funds and only included compensation paid through May 2022, resulting in understatement of the amounts on the FISAP by $1,232, which subsequently impacted the institutional and federal share reported on Section C and Section D of Part V of the form. Cause and Effect - A lack of documented role responsibilities, procedures, and review over the preparation of the forms caused a late filing and inaccurate information to be included on the FISAP. Recommendation - We recommend (1) the Seminary implement a review procedure of all students that are coded in the federal work study to ensure that they are eligible and (2) a formal review of the inputs of the FISAP is completed by a person independent from preparing the form. Views of Responsible Officials and Planned Corrective Actions - The financial aid director plans to have the FISAP completed and submitted by the required deadline of September 29, 2023. The Seminary will implement an independent second review of the FISAP, where the supporting records will be included.
Assistance Listing Number, Federal Agency, and Program Name - 84.038, U.S. Department of Education, Federal Perkins Loans Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2021-006 Criteria - The Seminary must (1) retain true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan (including Defense, NDSL) made and (2) retain disbursement records, electronic authentication, and signature records for loans made with an MPN in accordance in the manners set forth in 34 CFR 674.19(e). Condition - The Seminary was unable to support that required records were retained for outstanding Perkins loans. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The Seminary ceased using its third party servicer upon electing to liquidate the Perkins Loan Program in 2019, but the Seminary did not complete the liquidation process in a timely manner. Due to the delay in completion of the liquidation process until 2022, the Seminary did not retain the appropriate records from the servicer to appropriately track any of the remaining outstanding loans. Cause and Effect - The Seminary did not have formal procedures and controls over the Perkins Loan Program after the election to liquidate the program to retain the appropriate records, and, as a result, the remaining regulations were not followed by the Seminary. Recommendation - Although the Seminary has substantially completed the liquidation of the Perkins Loan Program during 2022, the Seminary should understand and maintain processes and controls over the programs the Seminary participates in to ensure compliance. Views of Responsible Officials and Planned Corrective Actions - The Seminary has finalized the closeout of the Perkins Loan Program (except for the audit final step, which is to be conducted as part of the 2022 audit). The Seminary has purchased the loans that were not accepted by the Department of Education.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.038, U.S. Department of Education, Federal Perkins Loans Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - In accordance with CFR 676.19 (b)(2) and (3), an institution should establish and maintain fiscal records that are reconciled at least monthly and each year the institution shall submit a fiscal operations report plus other information the secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the secretary. Condition - The Seminary did not have the appropriate procedures and controls in place to file an accurate and timely Fiscal Operations Report and Application to Participate (FISAP). Questioned Costs - N/A Context - The Seminary's FISAP was filed after the due date of September 30, 2022. In addition, the Seminary reported inaccurate information, including inaccurate Perkins loan awards, the number of students to whom federal work study was awarded, and the amount of compensation paid with federal funds. During our testing, the reports used to complete the FISAP included a student that was not eligible for federal work study funds and only included compensation paid through May 2022, resulting in understatement of the amounts on the FISAP by $1,232, which subsequently impacted the institutional and federal share reported on Section C and Section D of Part V of the form. Cause and Effect - A lack of documented role responsibilities, procedures, and review over the preparation of the forms caused a late filing and inaccurate information to be included on the FISAP. Recommendation - We recommend (1) the Seminary implement a review procedure of all students that are coded in the federal work study to ensure that they are eligible and (2) a formal review of the inputs of the FISAP is completed by a person independent from preparing the form. Views of Responsible Officials and Planned Corrective Actions - The financial aid director plans to have the FISAP completed and submitted by the required deadline of September 29, 2023. The Seminary will implement an independent second review of the FISAP, where the supporting records will be included.
Assistance Listing Number, Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2021-003 Criteria - The Seminary is required to perform monthly reconciliations of federal funding received between the Department of Education's records through the Common Origination and Disbursement (COD) and the Seminary's records. The Seminary is also required to have a formal review process in place to ensure the reconciliations are accurate and performed timely in accordance with 34 CFR 685.102(b), 685.301, and 303. Finally, the Seminary should have a quality assurance system in place in accordance with CFR 685.300(b)(9). Condition - During our review of internal controls and testing procedures, it was noted that there was no evidence that reconciliations were performed or reviewed during the fiscal year. In addition, the Seminary does not have a quality assurance system in place. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Due to the lack of reconciliations performed, no reconciliations were tested. In addition, the quality assurance system was not in place. Cause and Effect - The lack of maintaining and review of monthly reconciliations and lack of a quality assurance system could lead to differences between amounts reported to the Department of Education and amounts disbursed to the students that could go unidentified for a period of time. Recommendation - We recommend that policies be put in place to ensure reconciliations are maintained and that a formal review process be implemented and documented. In addition, we recommend that a quality assurance process be documented and implemented to ensure compliance with loan programs. Views of Responsible Officials and Corrective Action Plan - The financial aid director will implement an efficient procedure for monthly reconciliation using the new JFA system and COD. The first disbursement for 2023 2024 is planned for September; therefore, beginning on October 1, 2023, a new, efficient process will occur at the beginning of each month to reconcile federal funds. Financial aid will maintain copies of data to support the monthly reconciliation.
Assistance Listing Number, Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2021-004 Criteria - The Seminary must notify the student or parent in writing of the following related to the student's direct loan: (1) the date and amount of the disbursement; (2) the student's right, or parent's right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan in accordance with 34 CFR 668.165. Condition - Of the 16 students who received disbursements selected for testing, the Seminary did not notify 11 students or parents, as applicable, that received direct federal loans within the required 30 days. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Out of a sample of 16, our testing identified that, of 11 students who received federal direct loans, 1 was not notified at all and 10 were not notified timely because the Seminary did not have a process in place for the full year. Cause and Effect - The Seminary did not have formal procedures and controls in place to notify borrowers of their amounts, rights, and procedures related to the disbursement of federal direct loans for the full year. Recommendation - We recommend the Seminary maintain a procedure and control in place to ensure that, upon each disbursement of direct loans, the Seminary notifies the borrower of the required elements in accordance with the loan program. Views of Responsible Officials and Planned Corrective Actions - The financial aid director has already set up a disbursement notification email to be sent out of the new financial aid management system (JFA). Shortly after Title IV disbursements are made, the director will send out the disbursement notification to any group of students who have had aid disbursed. Each time a disbursement is made, these notifications will be sent to the necessary students. These notifications will be documented in each student's records.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness Repeat Finding - Yes - 2021-005 Criteria - The Seminary is required to maintain documentation of the initiation and approval by the designated individual at the Seminary that the cash drawdowns are certified in accordance with 2 CFR 200.415. Condition - Of the two drawdowns selected in our testing, the Seminary did not retain documentation to support one of the samples that the drawdown request was initiated, reviewed, and approved by the appropriate individuals. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - For all draws in the fiscal year that occurred prior to January 2022, the Seminary was relying solely on email communication between the student financial aid director and the bursar to support the requirements. The documentation does not meet the requirements to support that the Seminary is in compliance with the required regulations. Cause and Effect - The lack of maintaining records of the review and approval of the cash management process could lead to a lack of segregation of duties, as well as potential misstatement of funds, including funds being drawn on the incorrect grant, funds used for an unallowable cost, or funds recorded at an incorrect amount. Recommendation - We recommend the Seminary implement procedures and controls to ensure that drawdown documentation is maintained supporting that independent review was performed for each drawdown, including supporting documentation of approval of the cash drawdown. Views of Responsible Officials and Planned Corrective Actions - The financial aid director is implementing a procedure that will involve an email with supporting documentation for the drawdown requests sent to the CFO or VP of enrollment for review. The individual will sign a statement indicating the information has been reviewed and is accurate and the funds have been approved for drawdown. That email will then be forwarded to the controller to draw down the funds in G5. These requests/approvals will be documented in our internal office drawdown request folder.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness Repeat Finding - Yes - 2021-007 Criteria - The Seminary has 45 days from the date the college determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds. Withdrawal dates are defined as the time when the student officially withdrawals, or expresses notification to withdrawal, or if the student does not officially withdraw, the date the Seminary determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)). Condition - The Seminary did not have controls in place to identify and document the students who have withdrawn and the applicability of performing a return of Title IV funds. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The Seminary did not have a control in place to maintain documentation of the student financial aid department's review and consideration on the applicability of a return to title IV calculation. Subsequent to the fiscal year, the Seminary reviewed the original data files produced throughout the year by the registrar and updated documentation to support compliance. This assessment resulted in no students identified during testing that required a calculation to be performed. Cause and Effect - The Seminary did not have proper controls in place to identity and document students who have withdrawn from the Seminary. The lack of documentation around students who withdrew officially or unofficially led to the inability to support the compliance with the applicable code of federal regulations in a timely manner. Recommendation - The Seminary should implement a procedure that documents the Seminary's review of the student's individual facts and circumstances including, but not limited to, documenting the date of disbursement, the date of withdrawal, and the date of determination by the institution, whether the student is deemed an official or unofficial withdrawal. Views of Responsible Officials and Planned Corrective Actions - The financial aid director has created a spreadsheet to document detailed student information for withdrawals to include withdrawal date, whether federal funds were received, date R2T4 was calculated, if/how much unearned aid was returned, date processed, and any helpful notes for each student. The registrar will continue to email financial aid with any withdrawal details.
Assistance Listing Number, Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2021-009 Criteria - In accordance With 34 CFR ? 668.164 (h)(1), a Title IV, HEA credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed for the student for allowable charges associated with that payment period. A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) 14 days after the balance occurred if the credit balance occurred on the first day of class of a payment period or (ii) 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition - The Seminary did not maintain appropriate documentation to substantiate the allowable charges on the students ledger account to identity whether credit balances were created and required additional documentation from the student to hold the credit balance. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Out of a sample of 16, audit testing identified 3 students who had a Title IV credit balance and did not receive a timely refund. The Seminary did not have appropriate documentation to retain the credit balance. Cause and Effect - The Seminary's process for posting final charges until 30 days after the semester causes the inability to monitor credit balances on student accounts. Recommendation - We recommend the Seminary implement procedures to post the allowable charges to the students' accounts within a timely manner and prior to the disbursement of federal funds to the students. Views of Responsible Officials and Planned Corrective Actions - The Seminary will no longer be holding any credit balances for students. Any Title IV aid that is disbursed for 2023 2024 and creates a credit balance will be refunded to the student within 14 days of disbursement.
Assistance Listing Number, Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2021-003 Criteria - The Seminary is required to perform monthly reconciliations of federal funding received between the Department of Education's records through the Common Origination and Disbursement (COD) and the Seminary's records. The Seminary is also required to have a formal review process in place to ensure the reconciliations are accurate and performed timely in accordance with 34 CFR 685.102(b), 685.301, and 303. Finally, the Seminary should have a quality assurance system in place in accordance with CFR 685.300(b)(9). Condition - During our review of internal controls and testing procedures, it was noted that there was no evidence that reconciliations were performed or reviewed during the fiscal year. In addition, the Seminary does not have a quality assurance system in place. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Due to the lack of reconciliations performed, no reconciliations were tested. In addition, the quality assurance system was not in place. Cause and Effect - The lack of maintaining and review of monthly reconciliations and lack of a quality assurance system could lead to differences between amounts reported to the Department of Education and amounts disbursed to the students that could go unidentified for a period of time. Recommendation - We recommend that policies be put in place to ensure reconciliations are maintained and that a formal review process be implemented and documented. In addition, we recommend that a quality assurance process be documented and implemented to ensure compliance with loan programs. Views of Responsible Officials and Corrective Action Plan - The financial aid director will implement an efficient procedure for monthly reconciliation using the new JFA system and COD. The first disbursement for 2023 2024 is planned for September; therefore, beginning on October 1, 2023, a new, efficient process will occur at the beginning of each month to reconcile federal funds. Financial aid will maintain copies of data to support the monthly reconciliation.
Assistance Listing Number, Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2021-004 Criteria - The Seminary must notify the student or parent in writing of the following related to the student's direct loan: (1) the date and amount of the disbursement; (2) the student's right, or parent's right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan in accordance with 34 CFR 668.165. Condition - Of the 16 students who received disbursements selected for testing, the Seminary did not notify 11 students or parents, as applicable, that received direct federal loans within the required 30 days. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Out of a sample of 16, our testing identified that, of 11 students who received federal direct loans, 1 was not notified at all and 10 were not notified timely because the Seminary did not have a process in place for the full year. Cause and Effect - The Seminary did not have formal procedures and controls in place to notify borrowers of their amounts, rights, and procedures related to the disbursement of federal direct loans for the full year. Recommendation - We recommend the Seminary maintain a procedure and control in place to ensure that, upon each disbursement of direct loans, the Seminary notifies the borrower of the required elements in accordance with the loan program. Views of Responsible Officials and Planned Corrective Actions - The financial aid director has already set up a disbursement notification email to be sent out of the new financial aid management system (JFA). Shortly after Title IV disbursements are made, the director will send out the disbursement notification to any group of students who have had aid disbursed. Each time a disbursement is made, these notifications will be sent to the necessary students. These notifications will be documented in each student's records.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness Repeat Finding - Yes - 2021-005 Criteria - The Seminary is required to maintain documentation of the initiation and approval by the designated individual at the Seminary that the cash drawdowns are certified in accordance with 2 CFR 200.415. Condition - Of the two drawdowns selected in our testing, the Seminary did not retain documentation to support one of the samples that the drawdown request was initiated, reviewed, and approved by the appropriate individuals. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - For all draws in the fiscal year that occurred prior to January 2022, the Seminary was relying solely on email communication between the student financial aid director and the bursar to support the requirements. The documentation does not meet the requirements to support that the Seminary is in compliance with the required regulations. Cause and Effect - The lack of maintaining records of the review and approval of the cash management process could lead to a lack of segregation of duties, as well as potential misstatement of funds, including funds being drawn on the incorrect grant, funds used for an unallowable cost, or funds recorded at an incorrect amount. Recommendation - We recommend the Seminary implement procedures and controls to ensure that drawdown documentation is maintained supporting that independent review was performed for each drawdown, including supporting documentation of approval of the cash drawdown. Views of Responsible Officials and Planned Corrective Actions - The financial aid director is implementing a procedure that will involve an email with supporting documentation for the drawdown requests sent to the CFO or VP of enrollment for review. The individual will sign a statement indicating the information has been reviewed and is accurate and the funds have been approved for drawdown. That email will then be forwarded to the controller to draw down the funds in G5. These requests/approvals will be documented in our internal office drawdown request folder.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness Repeat Finding - Yes - 2021-007 Criteria - The Seminary has 45 days from the date the college determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds. Withdrawal dates are defined as the time when the student officially withdrawals, or expresses notification to withdrawal, or if the student does not officially withdraw, the date the Seminary determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)). Condition - The Seminary did not have controls in place to identify and document the students who have withdrawn and the applicability of performing a return of Title IV funds. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The Seminary did not have a control in place to maintain documentation of the student financial aid department's review and consideration on the applicability of a return to title IV calculation. Subsequent to the fiscal year, the Seminary reviewed the original data files produced throughout the year by the registrar and updated documentation to support compliance. This assessment resulted in no students identified during testing that required a calculation to be performed. Cause and Effect - The Seminary did not have proper controls in place to identity and document students who have withdrawn from the Seminary. The lack of documentation around students who withdrew officially or unofficially led to the inability to support the compliance with the applicable code of federal regulations in a timely manner. Recommendation - The Seminary should implement a procedure that documents the Seminary's review of the student's individual facts and circumstances including, but not limited to, documenting the date of disbursement, the date of withdrawal, and the date of determination by the institution, whether the student is deemed an official or unofficial withdrawal. Views of Responsible Officials and Planned Corrective Actions - The financial aid director has created a spreadsheet to document detailed student information for withdrawals to include withdrawal date, whether federal funds were received, date R2T4 was calculated, if/how much unearned aid was returned, date processed, and any helpful notes for each student. The registrar will continue to email financial aid with any withdrawal details.
Assistance Listing Number, Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2021-009 Criteria - In accordance With 34 CFR ? 668.164 (h)(1), a Title IV, HEA credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed for the student for allowable charges associated with that payment period. A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) 14 days after the balance occurred if the credit balance occurred on the first day of class of a payment period or (ii) 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition - The Seminary did not maintain appropriate documentation to substantiate the allowable charges on the students ledger account to identity whether credit balances were created and required additional documentation from the student to hold the credit balance. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Out of a sample of 16, audit testing identified 3 students who had a Title IV credit balance and did not receive a timely refund. The Seminary did not have appropriate documentation to retain the credit balance. Cause and Effect - The Seminary's process for posting final charges until 30 days after the semester causes the inability to monitor credit balances on student accounts. Recommendation - We recommend the Seminary implement procedures to post the allowable charges to the students' accounts within a timely manner and prior to the disbursement of federal funds to the students. Views of Responsible Officials and Planned Corrective Actions - The Seminary will no longer be holding any credit balances for students. Any Title IV aid that is disbursed for 2023 2024 and creates a credit balance will be refunded to the student within 14 days of disbursement.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness Repeat Finding - Yes - 2021-005 Criteria - The Seminary is required to maintain documentation of the initiation and approval by the designated individual at the Seminary that the cash drawdowns are certified in accordance with 2 CFR 200.415. Condition - Of the two drawdowns selected in our testing, the Seminary did not retain documentation to support one of the samples that the drawdown request was initiated, reviewed, and approved by the appropriate individuals. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - For all draws in the fiscal year that occurred prior to January 2022, the Seminary was relying solely on email communication between the student financial aid director and the bursar to support the requirements. The documentation does not meet the requirements to support that the Seminary is in compliance with the required regulations. Cause and Effect - The lack of maintaining records of the review and approval of the cash management process could lead to a lack of segregation of duties, as well as potential misstatement of funds, including funds being drawn on the incorrect grant, funds used for an unallowable cost, or funds recorded at an incorrect amount. Recommendation - We recommend the Seminary implement procedures and controls to ensure that drawdown documentation is maintained supporting that independent review was performed for each drawdown, including supporting documentation of approval of the cash drawdown. Views of Responsible Officials and Planned Corrective Actions - The financial aid director is implementing a procedure that will involve an email with supporting documentation for the drawdown requests sent to the CFO or VP of enrollment for review. The individual will sign a statement indicating the information has been reviewed and is accurate and the funds have been approved for drawdown. That email will then be forwarded to the controller to draw down the funds in G5. These requests/approvals will be documented in our internal office drawdown request folder.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness Repeat Finding - Yes - 2021-007 Criteria - The Seminary has 45 days from the date the college determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds. Withdrawal dates are defined as the time when the student officially withdrawals, or expresses notification to withdrawal, or if the student does not officially withdraw, the date the Seminary determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)). Condition - The Seminary did not have controls in place to identify and document the students who have withdrawn and the applicability of performing a return of Title IV funds. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The Seminary did not have a control in place to maintain documentation of the student financial aid department's review and consideration on the applicability of a return to title IV calculation. Subsequent to the fiscal year, the Seminary reviewed the original data files produced throughout the year by the registrar and updated documentation to support compliance. This assessment resulted in no students identified during testing that required a calculation to be performed. Cause and Effect - The Seminary did not have proper controls in place to identity and document students who have withdrawn from the Seminary. The lack of documentation around students who withdrew officially or unofficially led to the inability to support the compliance with the applicable code of federal regulations in a timely manner. Recommendation - The Seminary should implement a procedure that documents the Seminary's review of the student's individual facts and circumstances including, but not limited to, documenting the date of disbursement, the date of withdrawal, and the date of determination by the institution, whether the student is deemed an official or unofficial withdrawal. Views of Responsible Officials and Planned Corrective Actions - The financial aid director has created a spreadsheet to document detailed student information for withdrawals to include withdrawal date, whether federal funds were received, date R2T4 was calculated, if/how much unearned aid was returned, date processed, and any helpful notes for each student. The registrar will continue to email financial aid with any withdrawal details.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.038, U.S. Department of Education, Federal Perkins Loans Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - In accordance with CFR 676.19 (b)(2) and (3), an institution should establish and maintain fiscal records that are reconciled at least monthly and each year the institution shall submit a fiscal operations report plus other information the secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the secretary. Condition - The Seminary did not have the appropriate procedures and controls in place to file an accurate and timely Fiscal Operations Report and Application to Participate (FISAP). Questioned Costs - N/A Context - The Seminary's FISAP was filed after the due date of September 30, 2022. In addition, the Seminary reported inaccurate information, including inaccurate Perkins loan awards, the number of students to whom federal work study was awarded, and the amount of compensation paid with federal funds. During our testing, the reports used to complete the FISAP included a student that was not eligible for federal work study funds and only included compensation paid through May 2022, resulting in understatement of the amounts on the FISAP by $1,232, which subsequently impacted the institutional and federal share reported on Section C and Section D of Part V of the form. Cause and Effect - A lack of documented role responsibilities, procedures, and review over the preparation of the forms caused a late filing and inaccurate information to be included on the FISAP. Recommendation - We recommend (1) the Seminary implement a review procedure of all students that are coded in the federal work study to ensure that they are eligible and (2) a formal review of the inputs of the FISAP is completed by a person independent from preparing the form. Views of Responsible Officials and Planned Corrective Actions - The financial aid director plans to have the FISAP completed and submitted by the required deadline of September 29, 2023. The Seminary will implement an independent second review of the FISAP, where the supporting records will be included.
Assistance Listing Number, Federal Agency, and Program Name - 84.038, U.S. Department of Education, Federal Perkins Loans Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2021-006 Criteria - The Seminary must (1) retain true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan (including Defense, NDSL) made and (2) retain disbursement records, electronic authentication, and signature records for loans made with an MPN in accordance in the manners set forth in 34 CFR 674.19(e). Condition - The Seminary was unable to support that required records were retained for outstanding Perkins loans. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The Seminary ceased using its third party servicer upon electing to liquidate the Perkins Loan Program in 2019, but the Seminary did not complete the liquidation process in a timely manner. Due to the delay in completion of the liquidation process until 2022, the Seminary did not retain the appropriate records from the servicer to appropriately track any of the remaining outstanding loans. Cause and Effect - The Seminary did not have formal procedures and controls over the Perkins Loan Program after the election to liquidate the program to retain the appropriate records, and, as a result, the remaining regulations were not followed by the Seminary. Recommendation - Although the Seminary has substantially completed the liquidation of the Perkins Loan Program during 2022, the Seminary should understand and maintain processes and controls over the programs the Seminary participates in to ensure compliance. Views of Responsible Officials and Planned Corrective Actions - The Seminary has finalized the closeout of the Perkins Loan Program (except for the audit final step, which is to be conducted as part of the 2022 audit). The Seminary has purchased the loans that were not accepted by the Department of Education.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.038, U.S. Department of Education, Federal Perkins Loans Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - In accordance with CFR 676.19 (b)(2) and (3), an institution should establish and maintain fiscal records that are reconciled at least monthly and each year the institution shall submit a fiscal operations report plus other information the secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the secretary. Condition - The Seminary did not have the appropriate procedures and controls in place to file an accurate and timely Fiscal Operations Report and Application to Participate (FISAP). Questioned Costs - N/A Context - The Seminary's FISAP was filed after the due date of September 30, 2022. In addition, the Seminary reported inaccurate information, including inaccurate Perkins loan awards, the number of students to whom federal work study was awarded, and the amount of compensation paid with federal funds. During our testing, the reports used to complete the FISAP included a student that was not eligible for federal work study funds and only included compensation paid through May 2022, resulting in understatement of the amounts on the FISAP by $1,232, which subsequently impacted the institutional and federal share reported on Section C and Section D of Part V of the form. Cause and Effect - A lack of documented role responsibilities, procedures, and review over the preparation of the forms caused a late filing and inaccurate information to be included on the FISAP. Recommendation - We recommend (1) the Seminary implement a review procedure of all students that are coded in the federal work study to ensure that they are eligible and (2) a formal review of the inputs of the FISAP is completed by a person independent from preparing the form. Views of Responsible Officials and Planned Corrective Actions - The financial aid director plans to have the FISAP completed and submitted by the required deadline of September 29, 2023. The Seminary will implement an independent second review of the FISAP, where the supporting records will be included.
Assistance Listing Number, Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2021-003 Criteria - The Seminary is required to perform monthly reconciliations of federal funding received between the Department of Education's records through the Common Origination and Disbursement (COD) and the Seminary's records. The Seminary is also required to have a formal review process in place to ensure the reconciliations are accurate and performed timely in accordance with 34 CFR 685.102(b), 685.301, and 303. Finally, the Seminary should have a quality assurance system in place in accordance with CFR 685.300(b)(9). Condition - During our review of internal controls and testing procedures, it was noted that there was no evidence that reconciliations were performed or reviewed during the fiscal year. In addition, the Seminary does not have a quality assurance system in place. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Due to the lack of reconciliations performed, no reconciliations were tested. In addition, the quality assurance system was not in place. Cause and Effect - The lack of maintaining and review of monthly reconciliations and lack of a quality assurance system could lead to differences between amounts reported to the Department of Education and amounts disbursed to the students that could go unidentified for a period of time. Recommendation - We recommend that policies be put in place to ensure reconciliations are maintained and that a formal review process be implemented and documented. In addition, we recommend that a quality assurance process be documented and implemented to ensure compliance with loan programs. Views of Responsible Officials and Corrective Action Plan - The financial aid director will implement an efficient procedure for monthly reconciliation using the new JFA system and COD. The first disbursement for 2023 2024 is planned for September; therefore, beginning on October 1, 2023, a new, efficient process will occur at the beginning of each month to reconcile federal funds. Financial aid will maintain copies of data to support the monthly reconciliation.
Assistance Listing Number, Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2021-004 Criteria - The Seminary must notify the student or parent in writing of the following related to the student's direct loan: (1) the date and amount of the disbursement; (2) the student's right, or parent's right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan in accordance with 34 CFR 668.165. Condition - Of the 16 students who received disbursements selected for testing, the Seminary did not notify 11 students or parents, as applicable, that received direct federal loans within the required 30 days. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Out of a sample of 16, our testing identified that, of 11 students who received federal direct loans, 1 was not notified at all and 10 were not notified timely because the Seminary did not have a process in place for the full year. Cause and Effect - The Seminary did not have formal procedures and controls in place to notify borrowers of their amounts, rights, and procedures related to the disbursement of federal direct loans for the full year. Recommendation - We recommend the Seminary maintain a procedure and control in place to ensure that, upon each disbursement of direct loans, the Seminary notifies the borrower of the required elements in accordance with the loan program. Views of Responsible Officials and Planned Corrective Actions - The financial aid director has already set up a disbursement notification email to be sent out of the new financial aid management system (JFA). Shortly after Title IV disbursements are made, the director will send out the disbursement notification to any group of students who have had aid disbursed. Each time a disbursement is made, these notifications will be sent to the necessary students. These notifications will be documented in each student's records.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness Repeat Finding - Yes - 2021-005 Criteria - The Seminary is required to maintain documentation of the initiation and approval by the designated individual at the Seminary that the cash drawdowns are certified in accordance with 2 CFR 200.415. Condition - Of the two drawdowns selected in our testing, the Seminary did not retain documentation to support one of the samples that the drawdown request was initiated, reviewed, and approved by the appropriate individuals. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - For all draws in the fiscal year that occurred prior to January 2022, the Seminary was relying solely on email communication between the student financial aid director and the bursar to support the requirements. The documentation does not meet the requirements to support that the Seminary is in compliance with the required regulations. Cause and Effect - The lack of maintaining records of the review and approval of the cash management process could lead to a lack of segregation of duties, as well as potential misstatement of funds, including funds being drawn on the incorrect grant, funds used for an unallowable cost, or funds recorded at an incorrect amount. Recommendation - We recommend the Seminary implement procedures and controls to ensure that drawdown documentation is maintained supporting that independent review was performed for each drawdown, including supporting documentation of approval of the cash drawdown. Views of Responsible Officials and Planned Corrective Actions - The financial aid director is implementing a procedure that will involve an email with supporting documentation for the drawdown requests sent to the CFO or VP of enrollment for review. The individual will sign a statement indicating the information has been reviewed and is accurate and the funds have been approved for drawdown. That email will then be forwarded to the controller to draw down the funds in G5. These requests/approvals will be documented in our internal office drawdown request folder.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness Repeat Finding - Yes - 2021-007 Criteria - The Seminary has 45 days from the date the college determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds. Withdrawal dates are defined as the time when the student officially withdrawals, or expresses notification to withdrawal, or if the student does not officially withdraw, the date the Seminary determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)). Condition - The Seminary did not have controls in place to identify and document the students who have withdrawn and the applicability of performing a return of Title IV funds. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The Seminary did not have a control in place to maintain documentation of the student financial aid department's review and consideration on the applicability of a return to title IV calculation. Subsequent to the fiscal year, the Seminary reviewed the original data files produced throughout the year by the registrar and updated documentation to support compliance. This assessment resulted in no students identified during testing that required a calculation to be performed. Cause and Effect - The Seminary did not have proper controls in place to identity and document students who have withdrawn from the Seminary. The lack of documentation around students who withdrew officially or unofficially led to the inability to support the compliance with the applicable code of federal regulations in a timely manner. Recommendation - The Seminary should implement a procedure that documents the Seminary's review of the student's individual facts and circumstances including, but not limited to, documenting the date of disbursement, the date of withdrawal, and the date of determination by the institution, whether the student is deemed an official or unofficial withdrawal. Views of Responsible Officials and Planned Corrective Actions - The financial aid director has created a spreadsheet to document detailed student information for withdrawals to include withdrawal date, whether federal funds were received, date R2T4 was calculated, if/how much unearned aid was returned, date processed, and any helpful notes for each student. The registrar will continue to email financial aid with any withdrawal details.
Assistance Listing Number, Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2021-009 Criteria - In accordance With 34 CFR ? 668.164 (h)(1), a Title IV, HEA credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed for the student for allowable charges associated with that payment period. A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) 14 days after the balance occurred if the credit balance occurred on the first day of class of a payment period or (ii) 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition - The Seminary did not maintain appropriate documentation to substantiate the allowable charges on the students ledger account to identity whether credit balances were created and required additional documentation from the student to hold the credit balance. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Out of a sample of 16, audit testing identified 3 students who had a Title IV credit balance and did not receive a timely refund. The Seminary did not have appropriate documentation to retain the credit balance. Cause and Effect - The Seminary's process for posting final charges until 30 days after the semester causes the inability to monitor credit balances on student accounts. Recommendation - We recommend the Seminary implement procedures to post the allowable charges to the students' accounts within a timely manner and prior to the disbursement of federal funds to the students. Views of Responsible Officials and Planned Corrective Actions - The Seminary will no longer be holding any credit balances for students. Any Title IV aid that is disbursed for 2023 2024 and creates a credit balance will be refunded to the student within 14 days of disbursement.
Assistance Listing Number, Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2021-003 Criteria - The Seminary is required to perform monthly reconciliations of federal funding received between the Department of Education's records through the Common Origination and Disbursement (COD) and the Seminary's records. The Seminary is also required to have a formal review process in place to ensure the reconciliations are accurate and performed timely in accordance with 34 CFR 685.102(b), 685.301, and 303. Finally, the Seminary should have a quality assurance system in place in accordance with CFR 685.300(b)(9). Condition - During our review of internal controls and testing procedures, it was noted that there was no evidence that reconciliations were performed or reviewed during the fiscal year. In addition, the Seminary does not have a quality assurance system in place. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Due to the lack of reconciliations performed, no reconciliations were tested. In addition, the quality assurance system was not in place. Cause and Effect - The lack of maintaining and review of monthly reconciliations and lack of a quality assurance system could lead to differences between amounts reported to the Department of Education and amounts disbursed to the students that could go unidentified for a period of time. Recommendation - We recommend that policies be put in place to ensure reconciliations are maintained and that a formal review process be implemented and documented. In addition, we recommend that a quality assurance process be documented and implemented to ensure compliance with loan programs. Views of Responsible Officials and Corrective Action Plan - The financial aid director will implement an efficient procedure for monthly reconciliation using the new JFA system and COD. The first disbursement for 2023 2024 is planned for September; therefore, beginning on October 1, 2023, a new, efficient process will occur at the beginning of each month to reconcile federal funds. Financial aid will maintain copies of data to support the monthly reconciliation.
Assistance Listing Number, Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2021-004 Criteria - The Seminary must notify the student or parent in writing of the following related to the student's direct loan: (1) the date and amount of the disbursement; (2) the student's right, or parent's right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan in accordance with 34 CFR 668.165. Condition - Of the 16 students who received disbursements selected for testing, the Seminary did not notify 11 students or parents, as applicable, that received direct federal loans within the required 30 days. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Out of a sample of 16, our testing identified that, of 11 students who received federal direct loans, 1 was not notified at all and 10 were not notified timely because the Seminary did not have a process in place for the full year. Cause and Effect - The Seminary did not have formal procedures and controls in place to notify borrowers of their amounts, rights, and procedures related to the disbursement of federal direct loans for the full year. Recommendation - We recommend the Seminary maintain a procedure and control in place to ensure that, upon each disbursement of direct loans, the Seminary notifies the borrower of the required elements in accordance with the loan program. Views of Responsible Officials and Planned Corrective Actions - The financial aid director has already set up a disbursement notification email to be sent out of the new financial aid management system (JFA). Shortly after Title IV disbursements are made, the director will send out the disbursement notification to any group of students who have had aid disbursed. Each time a disbursement is made, these notifications will be sent to the necessary students. These notifications will be documented in each student's records.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness Repeat Finding - Yes - 2021-005 Criteria - The Seminary is required to maintain documentation of the initiation and approval by the designated individual at the Seminary that the cash drawdowns are certified in accordance with 2 CFR 200.415. Condition - Of the two drawdowns selected in our testing, the Seminary did not retain documentation to support one of the samples that the drawdown request was initiated, reviewed, and approved by the appropriate individuals. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - For all draws in the fiscal year that occurred prior to January 2022, the Seminary was relying solely on email communication between the student financial aid director and the bursar to support the requirements. The documentation does not meet the requirements to support that the Seminary is in compliance with the required regulations. Cause and Effect - The lack of maintaining records of the review and approval of the cash management process could lead to a lack of segregation of duties, as well as potential misstatement of funds, including funds being drawn on the incorrect grant, funds used for an unallowable cost, or funds recorded at an incorrect amount. Recommendation - We recommend the Seminary implement procedures and controls to ensure that drawdown documentation is maintained supporting that independent review was performed for each drawdown, including supporting documentation of approval of the cash drawdown. Views of Responsible Officials and Planned Corrective Actions - The financial aid director is implementing a procedure that will involve an email with supporting documentation for the drawdown requests sent to the CFO or VP of enrollment for review. The individual will sign a statement indicating the information has been reviewed and is accurate and the funds have been approved for drawdown. That email will then be forwarded to the controller to draw down the funds in G5. These requests/approvals will be documented in our internal office drawdown request folder.
Assistance Listing Number, Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness Repeat Finding - Yes - 2021-007 Criteria - The Seminary has 45 days from the date the college determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds. Withdrawal dates are defined as the time when the student officially withdrawals, or expresses notification to withdrawal, or if the student does not officially withdraw, the date the Seminary determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)). Condition - The Seminary did not have controls in place to identify and document the students who have withdrawn and the applicability of performing a return of Title IV funds. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The Seminary did not have a control in place to maintain documentation of the student financial aid department's review and consideration on the applicability of a return to title IV calculation. Subsequent to the fiscal year, the Seminary reviewed the original data files produced throughout the year by the registrar and updated documentation to support compliance. This assessment resulted in no students identified during testing that required a calculation to be performed. Cause and Effect - The Seminary did not have proper controls in place to identity and document students who have withdrawn from the Seminary. The lack of documentation around students who withdrew officially or unofficially led to the inability to support the compliance with the applicable code of federal regulations in a timely manner. Recommendation - The Seminary should implement a procedure that documents the Seminary's review of the student's individual facts and circumstances including, but not limited to, documenting the date of disbursement, the date of withdrawal, and the date of determination by the institution, whether the student is deemed an official or unofficial withdrawal. Views of Responsible Officials and Planned Corrective Actions - The financial aid director has created a spreadsheet to document detailed student information for withdrawals to include withdrawal date, whether federal funds were received, date R2T4 was calculated, if/how much unearned aid was returned, date processed, and any helpful notes for each student. The registrar will continue to email financial aid with any withdrawal details.
Assistance Listing Number, Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2021-009 Criteria - In accordance With 34 CFR ? 668.164 (h)(1), a Title IV, HEA credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed for the student for allowable charges associated with that payment period. A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) 14 days after the balance occurred if the credit balance occurred on the first day of class of a payment period or (ii) 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition - The Seminary did not maintain appropriate documentation to substantiate the allowable charges on the students ledger account to identity whether credit balances were created and required additional documentation from the student to hold the credit balance. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Out of a sample of 16, audit testing identified 3 students who had a Title IV credit balance and did not receive a timely refund. The Seminary did not have appropriate documentation to retain the credit balance. Cause and Effect - The Seminary's process for posting final charges until 30 days after the semester causes the inability to monitor credit balances on student accounts. Recommendation - We recommend the Seminary implement procedures to post the allowable charges to the students' accounts within a timely manner and prior to the disbursement of federal funds to the students. Views of Responsible Officials and Planned Corrective Actions - The Seminary will no longer be holding any credit balances for students. Any Title IV aid that is disbursed for 2023 2024 and creates a credit balance will be refunded to the student within 14 days of disbursement.