FINDING 2022-001?Eligibility: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? 2 CFR 200.303 Internal controls ? The non-federal entity must: (a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/context ? A sample of 10 students was selected from the population of all students who were awarded and disbursed federal student financial aid funds from American Jewish University (the ?University?) during the year ended June 30, 2022. For those students who had Institutional Student Informational Record (ISIR) flags which are required to be cleared, we requested supporting evidence that the flags were cleared. The University did not have effective internal control in place to ensure ISIR flags had been cleared. Cause ? Individuals responsible for awarding and packaging students were unaware of the requirement to clear ISIR flags. Effect ? Without established effective preventative controls in place, the University could become out of compliance with federal rules and regulations. Repeat finding ? This is not a repeat finding. Recommendation ? We recommend the University include a written process for identifying and clearing ISIR flags in their written policy and procedures manual. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
FINDING 2022-003?Special Tests and Provisions?Disbursements: Significant Deficiency in Internal Control Over Compliance "See Schedule of Findings and Questioned Costs for chart/table." Criteria ? 34 CFR 668.164 Disbursing funds ? (h) Title IV, HEA credit balances. (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 the student for allowable charges associated with that payment period as provided under paragraph (c) of this section. (2) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than: (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (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/context ? A sample of 10 students was selected from the population of all students disbursed federal student financial aid by the University during the year ended June 30, 2022. We obtained the students records and tested the student?s compliance with federal regulations for the specific loans and grants for which each individual student was disbursed. For one undergraduate student selected, federal student aid was disbursed, creating a credit balance which was not refunded to the student within the 14-day requirement. Cause ? Due to turnover in the position responsible for monitoring credit balances and disbursement date compliance requirements, individuals performing the responsibility were unable to perform the task according to the required timeframes. Effect ? The University was not in compliance with disbursement requirements. Repeat finding ? This is a repeat finding. See 2021-003. Recommendation ? We recommend the University revise its policies to establish cross-training protocols for responsibilities related to disbursement of federal aid. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters. It also enables us to communicate effectively with the accounting office and ensure disbursements and refunds are processed timely and in accordance with the Department of Education rules and regulations.
FINDING 2022-004?Special Tests and Provisions?Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "See Schedule of Findings and Questioned Costs for chart/table." Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/context ? A sample of 3 federal aid recipient students was selected from reports of students who graduated during the 2021-2022 academic year. There were no students who withdrew or dropped during the 2021-2022 academic year. The enrollment information and withdrawal or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the status change of 1 graduated student selected for testing was not reported to the NSLDS. Cause ? Due to turnover in the position responsible for performing the manual reporting process, reporting was not completed until the responsibility was assigned to a new employee. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat finding ? This is a repeat finding. See 2021-005. Recommendation ? We recommend the University revise its policies to establish cross-training protocols for responsibilities that contain strict deadlines. Views of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
FINDING 2022-001?Eligibility: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? 2 CFR 200.303 Internal controls ? The non-federal entity must: (a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/context ? A sample of 10 students was selected from the population of all students who were awarded and disbursed federal student financial aid funds from American Jewish University (the ?University?) during the year ended June 30, 2022. For those students who had Institutional Student Informational Record (ISIR) flags which are required to be cleared, we requested supporting evidence that the flags were cleared. The University did not have effective internal control in place to ensure ISIR flags had been cleared. Cause ? Individuals responsible for awarding and packaging students were unaware of the requirement to clear ISIR flags. Effect ? Without established effective preventative controls in place, the University could become out of compliance with federal rules and regulations. Repeat finding ? This is not a repeat finding. Recommendation ? We recommend the University include a written process for identifying and clearing ISIR flags in their written policy and procedures manual. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
FINDING 2022-003?Special Tests and Provisions?Disbursements: Significant Deficiency in Internal Control Over Compliance "See Schedule of Findings and Questioned Costs for chart/table." Criteria ? 34 CFR 668.164 Disbursing funds ? (h) Title IV, HEA credit balances. (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 the student for allowable charges associated with that payment period as provided under paragraph (c) of this section. (2) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than: (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (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/context ? A sample of 10 students was selected from the population of all students disbursed federal student financial aid by the University during the year ended June 30, 2022. We obtained the students records and tested the student?s compliance with federal regulations for the specific loans and grants for which each individual student was disbursed. For one undergraduate student selected, federal student aid was disbursed, creating a credit balance which was not refunded to the student within the 14-day requirement. Cause ? Due to turnover in the position responsible for monitoring credit balances and disbursement date compliance requirements, individuals performing the responsibility were unable to perform the task according to the required timeframes. Effect ? The University was not in compliance with disbursement requirements. Repeat finding ? This is a repeat finding. See 2021-003. Recommendation ? We recommend the University revise its policies to establish cross-training protocols for responsibilities related to disbursement of federal aid. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters. It also enables us to communicate effectively with the accounting office and ensure disbursements and refunds are processed timely and in accordance with the Department of Education rules and regulations.
FINDING 2022-004?Special Tests and Provisions?Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "See Schedule of Findings and Questioned Costs for chart/table." Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/context ? A sample of 3 federal aid recipient students was selected from reports of students who graduated during the 2021-2022 academic year. There were no students who withdrew or dropped during the 2021-2022 academic year. The enrollment information and withdrawal or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the status change of 1 graduated student selected for testing was not reported to the NSLDS. Cause ? Due to turnover in the position responsible for performing the manual reporting process, reporting was not completed until the responsibility was assigned to a new employee. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat finding ? This is a repeat finding. See 2021-005. Recommendation ? We recommend the University revise its policies to establish cross-training protocols for responsibilities that contain strict deadlines. Views of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
FINDING 2022-001?Eligibility: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? 2 CFR 200.303 Internal controls ? The non-federal entity must: (a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/context ? A sample of 10 students was selected from the population of all students who were awarded and disbursed federal student financial aid funds from American Jewish University (the ?University?) during the year ended June 30, 2022. For those students who had Institutional Student Informational Record (ISIR) flags which are required to be cleared, we requested supporting evidence that the flags were cleared. The University did not have effective internal control in place to ensure ISIR flags had been cleared. Cause ? Individuals responsible for awarding and packaging students were unaware of the requirement to clear ISIR flags. Effect ? Without established effective preventative controls in place, the University could become out of compliance with federal rules and regulations. Repeat finding ? This is not a repeat finding. Recommendation ? We recommend the University include a written process for identifying and clearing ISIR flags in their written policy and procedures manual. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
FINDING 2022-003?Special Tests and Provisions?Disbursements: Significant Deficiency in Internal Control Over Compliance "See Schedule of Findings and Questioned Costs for chart/table." Criteria ? 34 CFR 668.164 Disbursing funds ? (h) Title IV, HEA credit balances. (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 the student for allowable charges associated with that payment period as provided under paragraph (c) of this section. (2) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than: (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (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/context ? A sample of 10 students was selected from the population of all students disbursed federal student financial aid by the University during the year ended June 30, 2022. We obtained the students records and tested the student?s compliance with federal regulations for the specific loans and grants for which each individual student was disbursed. For one undergraduate student selected, federal student aid was disbursed, creating a credit balance which was not refunded to the student within the 14-day requirement. Cause ? Due to turnover in the position responsible for monitoring credit balances and disbursement date compliance requirements, individuals performing the responsibility were unable to perform the task according to the required timeframes. Effect ? The University was not in compliance with disbursement requirements. Repeat finding ? This is a repeat finding. See 2021-003. Recommendation ? We recommend the University revise its policies to establish cross-training protocols for responsibilities related to disbursement of federal aid. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters. It also enables us to communicate effectively with the accounting office and ensure disbursements and refunds are processed timely and in accordance with the Department of Education rules and regulations.
FINDING 2022-004?Special Tests and Provisions?Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "See Schedule of Findings and Questioned Costs for chart/table." Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/context ? A sample of 3 federal aid recipient students was selected from reports of students who graduated during the 2021-2022 academic year. There were no students who withdrew or dropped during the 2021-2022 academic year. The enrollment information and withdrawal or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the status change of 1 graduated student selected for testing was not reported to the NSLDS. Cause ? Due to turnover in the position responsible for performing the manual reporting process, reporting was not completed until the responsibility was assigned to a new employee. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat finding ? This is a repeat finding. See 2021-005. Recommendation ? We recommend the University revise its policies to establish cross-training protocols for responsibilities that contain strict deadlines. Views of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
FINDING 2022-001?Eligibility: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? 2 CFR 200.303 Internal controls ? The non-federal entity must: (a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/context ? A sample of 10 students was selected from the population of all students who were awarded and disbursed federal student financial aid funds from American Jewish University (the ?University?) during the year ended June 30, 2022. For those students who had Institutional Student Informational Record (ISIR) flags which are required to be cleared, we requested supporting evidence that the flags were cleared. The University did not have effective internal control in place to ensure ISIR flags had been cleared. Cause ? Individuals responsible for awarding and packaging students were unaware of the requirement to clear ISIR flags. Effect ? Without established effective preventative controls in place, the University could become out of compliance with federal rules and regulations. Repeat finding ? This is not a repeat finding. Recommendation ? We recommend the University include a written process for identifying and clearing ISIR flags in their written policy and procedures manual. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
FINDING 2022-002?Special Tests and Provisions?Borrower Data Transmission and Reconciliation: Material Weakness in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? 34 CFR 685.300 Program participation agreement ? On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Condition/context ? A sample of 4 direct loan reconciliations were selected from the population of all reconciliations performed by the University during the year ended June 30, 2022. We obtained the supporting schedules used to reconcile the disbursed direct loan funds to the federal government?s records. The University did not have effective internal control in place that would provide reasonable assurance that the University was in compliance with federal regulations and the University did not complete reconciliations for all of 2022 with the exception of March 2022. Cause ? Management did not have an established policy and procedure for borrower data transmission and reconciliation. Further, due to turnover in the position responsible for performing the monthly reconciliation, the process was not completed in the noted months. Effect ? Without established effective controls in place, the University could become out of compliance with federal rules and regulations. Repeat finding ? This is a repeat finding. See 2021-002. Recommendation ? We recommend the University establish an internal control such as supervisory review of the monthly direct loan reconciliation. The reviewer should obtain the supporting schedules used to reconcile University records to federal records and investigate any discrepancies or transactions that may indicate non-compliance. Further, the University should identify other individuals to perform the monthly reconciliation should there be illness or turnover. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership will ensure monthly loan reconciliations are performed on time and approved by the CFO.
FINDING 2022-003?Special Tests and Provisions?Disbursements: Significant Deficiency in Internal Control Over Compliance "See Schedule of Findings and Questioned Costs for chart/table." Criteria ? 34 CFR 668.164 Disbursing funds ? (h) Title IV, HEA credit balances. (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 the student for allowable charges associated with that payment period as provided under paragraph (c) of this section. (2) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than: (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (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/context ? A sample of 10 students was selected from the population of all students disbursed federal student financial aid by the University during the year ended June 30, 2022. We obtained the students records and tested the student?s compliance with federal regulations for the specific loans and grants for which each individual student was disbursed. For one undergraduate student selected, federal student aid was disbursed, creating a credit balance which was not refunded to the student within the 14-day requirement. Cause ? Due to turnover in the position responsible for monitoring credit balances and disbursement date compliance requirements, individuals performing the responsibility were unable to perform the task according to the required timeframes. Effect ? The University was not in compliance with disbursement requirements. Repeat finding ? This is a repeat finding. See 2021-003. Recommendation ? We recommend the University revise its policies to establish cross-training protocols for responsibilities related to disbursement of federal aid. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters. It also enables us to communicate effectively with the accounting office and ensure disbursements and refunds are processed timely and in accordance with the Department of Education rules and regulations.
FINDING 2022-004?Special Tests and Provisions?Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "See Schedule of Findings and Questioned Costs for chart/table." Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/context ? A sample of 3 federal aid recipient students was selected from reports of students who graduated during the 2021-2022 academic year. There were no students who withdrew or dropped during the 2021-2022 academic year. The enrollment information and withdrawal or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the status change of 1 graduated student selected for testing was not reported to the NSLDS. Cause ? Due to turnover in the position responsible for performing the manual reporting process, reporting was not completed until the responsibility was assigned to a new employee. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat finding ? This is a repeat finding. See 2021-005. Recommendation ? We recommend the University revise its policies to establish cross-training protocols for responsibilities that contain strict deadlines. Views of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
FINDING 2022-001?Eligibility: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? 2 CFR 200.303 Internal controls ? The non-federal entity must: (a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/context ? A sample of 10 students was selected from the population of all students who were awarded and disbursed federal student financial aid funds from American Jewish University (the ?University?) during the year ended June 30, 2022. For those students who had Institutional Student Informational Record (ISIR) flags which are required to be cleared, we requested supporting evidence that the flags were cleared. The University did not have effective internal control in place to ensure ISIR flags had been cleared. Cause ? Individuals responsible for awarding and packaging students were unaware of the requirement to clear ISIR flags. Effect ? Without established effective preventative controls in place, the University could become out of compliance with federal rules and regulations. Repeat finding ? This is not a repeat finding. Recommendation ? We recommend the University include a written process for identifying and clearing ISIR flags in their written policy and procedures manual. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
FINDING 2022-003?Special Tests and Provisions?Disbursements: Significant Deficiency in Internal Control Over Compliance "See Schedule of Findings and Questioned Costs for chart/table." Criteria ? 34 CFR 668.164 Disbursing funds ? (h) Title IV, HEA credit balances. (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 the student for allowable charges associated with that payment period as provided under paragraph (c) of this section. (2) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than: (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (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/context ? A sample of 10 students was selected from the population of all students disbursed federal student financial aid by the University during the year ended June 30, 2022. We obtained the students records and tested the student?s compliance with federal regulations for the specific loans and grants for which each individual student was disbursed. For one undergraduate student selected, federal student aid was disbursed, creating a credit balance which was not refunded to the student within the 14-day requirement. Cause ? Due to turnover in the position responsible for monitoring credit balances and disbursement date compliance requirements, individuals performing the responsibility were unable to perform the task according to the required timeframes. Effect ? The University was not in compliance with disbursement requirements. Repeat finding ? This is a repeat finding. See 2021-003. Recommendation ? We recommend the University revise its policies to establish cross-training protocols for responsibilities related to disbursement of federal aid. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters. It also enables us to communicate effectively with the accounting office and ensure disbursements and refunds are processed timely and in accordance with the Department of Education rules and regulations.
FINDING 2022-004?Special Tests and Provisions?Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "See Schedule of Findings and Questioned Costs for chart/table." Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/context ? A sample of 3 federal aid recipient students was selected from reports of students who graduated during the 2021-2022 academic year. There were no students who withdrew or dropped during the 2021-2022 academic year. The enrollment information and withdrawal or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the status change of 1 graduated student selected for testing was not reported to the NSLDS. Cause ? Due to turnover in the position responsible for performing the manual reporting process, reporting was not completed until the responsibility was assigned to a new employee. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat finding ? This is a repeat finding. See 2021-005. Recommendation ? We recommend the University revise its policies to establish cross-training protocols for responsibilities that contain strict deadlines. Views of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
FINDING 2022-001?Eligibility: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? 2 CFR 200.303 Internal controls ? The non-federal entity must: (a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/context ? A sample of 10 students was selected from the population of all students who were awarded and disbursed federal student financial aid funds from American Jewish University (the ?University?) during the year ended June 30, 2022. For those students who had Institutional Student Informational Record (ISIR) flags which are required to be cleared, we requested supporting evidence that the flags were cleared. The University did not have effective internal control in place to ensure ISIR flags had been cleared. Cause ? Individuals responsible for awarding and packaging students were unaware of the requirement to clear ISIR flags. Effect ? Without established effective preventative controls in place, the University could become out of compliance with federal rules and regulations. Repeat finding ? This is not a repeat finding. Recommendation ? We recommend the University include a written process for identifying and clearing ISIR flags in their written policy and procedures manual. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
FINDING 2022-003?Special Tests and Provisions?Disbursements: Significant Deficiency in Internal Control Over Compliance "See Schedule of Findings and Questioned Costs for chart/table." Criteria ? 34 CFR 668.164 Disbursing funds ? (h) Title IV, HEA credit balances. (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 the student for allowable charges associated with that payment period as provided under paragraph (c) of this section. (2) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than: (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (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/context ? A sample of 10 students was selected from the population of all students disbursed federal student financial aid by the University during the year ended June 30, 2022. We obtained the students records and tested the student?s compliance with federal regulations for the specific loans and grants for which each individual student was disbursed. For one undergraduate student selected, federal student aid was disbursed, creating a credit balance which was not refunded to the student within the 14-day requirement. Cause ? Due to turnover in the position responsible for monitoring credit balances and disbursement date compliance requirements, individuals performing the responsibility were unable to perform the task according to the required timeframes. Effect ? The University was not in compliance with disbursement requirements. Repeat finding ? This is a repeat finding. See 2021-003. Recommendation ? We recommend the University revise its policies to establish cross-training protocols for responsibilities related to disbursement of federal aid. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters. It also enables us to communicate effectively with the accounting office and ensure disbursements and refunds are processed timely and in accordance with the Department of Education rules and regulations.
FINDING 2022-004?Special Tests and Provisions?Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "See Schedule of Findings and Questioned Costs for chart/table." Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/context ? A sample of 3 federal aid recipient students was selected from reports of students who graduated during the 2021-2022 academic year. There were no students who withdrew or dropped during the 2021-2022 academic year. The enrollment information and withdrawal or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the status change of 1 graduated student selected for testing was not reported to the NSLDS. Cause ? Due to turnover in the position responsible for performing the manual reporting process, reporting was not completed until the responsibility was assigned to a new employee. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat finding ? This is a repeat finding. See 2021-005. Recommendation ? We recommend the University revise its policies to establish cross-training protocols for responsibilities that contain strict deadlines. Views of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
FINDING 2022-001?Eligibility: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? 2 CFR 200.303 Internal controls ? The non-federal entity must: (a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/context ? A sample of 10 students was selected from the population of all students who were awarded and disbursed federal student financial aid funds from American Jewish University (the ?University?) during the year ended June 30, 2022. For those students who had Institutional Student Informational Record (ISIR) flags which are required to be cleared, we requested supporting evidence that the flags were cleared. The University did not have effective internal control in place to ensure ISIR flags had been cleared. Cause ? Individuals responsible for awarding and packaging students were unaware of the requirement to clear ISIR flags. Effect ? Without established effective preventative controls in place, the University could become out of compliance with federal rules and regulations. Repeat finding ? This is not a repeat finding. Recommendation ? We recommend the University include a written process for identifying and clearing ISIR flags in their written policy and procedures manual. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
FINDING 2022-003?Special Tests and Provisions?Disbursements: Significant Deficiency in Internal Control Over Compliance "See Schedule of Findings and Questioned Costs for chart/table." Criteria ? 34 CFR 668.164 Disbursing funds ? (h) Title IV, HEA credit balances. (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 the student for allowable charges associated with that payment period as provided under paragraph (c) of this section. (2) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than: (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (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/context ? A sample of 10 students was selected from the population of all students disbursed federal student financial aid by the University during the year ended June 30, 2022. We obtained the students records and tested the student?s compliance with federal regulations for the specific loans and grants for which each individual student was disbursed. For one undergraduate student selected, federal student aid was disbursed, creating a credit balance which was not refunded to the student within the 14-day requirement. Cause ? Due to turnover in the position responsible for monitoring credit balances and disbursement date compliance requirements, individuals performing the responsibility were unable to perform the task according to the required timeframes. Effect ? The University was not in compliance with disbursement requirements. Repeat finding ? This is a repeat finding. See 2021-003. Recommendation ? We recommend the University revise its policies to establish cross-training protocols for responsibilities related to disbursement of federal aid. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters. It also enables us to communicate effectively with the accounting office and ensure disbursements and refunds are processed timely and in accordance with the Department of Education rules and regulations.
FINDING 2022-004?Special Tests and Provisions?Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "See Schedule of Findings and Questioned Costs for chart/table." Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/context ? A sample of 3 federal aid recipient students was selected from reports of students who graduated during the 2021-2022 academic year. There were no students who withdrew or dropped during the 2021-2022 academic year. The enrollment information and withdrawal or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the status change of 1 graduated student selected for testing was not reported to the NSLDS. Cause ? Due to turnover in the position responsible for performing the manual reporting process, reporting was not completed until the responsibility was assigned to a new employee. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat finding ? This is a repeat finding. See 2021-005. Recommendation ? We recommend the University revise its policies to establish cross-training protocols for responsibilities that contain strict deadlines. Views of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
FINDING 2022-001?Eligibility: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? 2 CFR 200.303 Internal controls ? The non-federal entity must: (a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/context ? A sample of 10 students was selected from the population of all students who were awarded and disbursed federal student financial aid funds from American Jewish University (the ?University?) during the year ended June 30, 2022. For those students who had Institutional Student Informational Record (ISIR) flags which are required to be cleared, we requested supporting evidence that the flags were cleared. The University did not have effective internal control in place to ensure ISIR flags had been cleared. Cause ? Individuals responsible for awarding and packaging students were unaware of the requirement to clear ISIR flags. Effect ? Without established effective preventative controls in place, the University could become out of compliance with federal rules and regulations. Repeat finding ? This is not a repeat finding. Recommendation ? We recommend the University include a written process for identifying and clearing ISIR flags in their written policy and procedures manual. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.
FINDING 2022-002?Special Tests and Provisions?Borrower Data Transmission and Reconciliation: Material Weakness in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? 34 CFR 685.300 Program participation agreement ? On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Condition/context ? A sample of 4 direct loan reconciliations were selected from the population of all reconciliations performed by the University during the year ended June 30, 2022. We obtained the supporting schedules used to reconcile the disbursed direct loan funds to the federal government?s records. The University did not have effective internal control in place that would provide reasonable assurance that the University was in compliance with federal regulations and the University did not complete reconciliations for all of 2022 with the exception of March 2022. Cause ? Management did not have an established policy and procedure for borrower data transmission and reconciliation. Further, due to turnover in the position responsible for performing the monthly reconciliation, the process was not completed in the noted months. Effect ? Without established effective controls in place, the University could become out of compliance with federal rules and regulations. Repeat finding ? This is a repeat finding. See 2021-002. Recommendation ? We recommend the University establish an internal control such as supervisory review of the monthly direct loan reconciliation. The reviewer should obtain the supporting schedules used to reconcile University records to federal records and investigate any discrepancies or transactions that may indicate non-compliance. Further, the University should identify other individuals to perform the monthly reconciliation should there be illness or turnover. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership will ensure monthly loan reconciliations are performed on time and approved by the CFO.
FINDING 2022-003?Special Tests and Provisions?Disbursements: Significant Deficiency in Internal Control Over Compliance "See Schedule of Findings and Questioned Costs for chart/table." Criteria ? 34 CFR 668.164 Disbursing funds ? (h) Title IV, HEA credit balances. (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 the student for allowable charges associated with that payment period as provided under paragraph (c) of this section. (2) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than: (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (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/context ? A sample of 10 students was selected from the population of all students disbursed federal student financial aid by the University during the year ended June 30, 2022. We obtained the students records and tested the student?s compliance with federal regulations for the specific loans and grants for which each individual student was disbursed. For one undergraduate student selected, federal student aid was disbursed, creating a credit balance which was not refunded to the student within the 14-day requirement. Cause ? Due to turnover in the position responsible for monitoring credit balances and disbursement date compliance requirements, individuals performing the responsibility were unable to perform the task according to the required timeframes. Effect ? The University was not in compliance with disbursement requirements. Repeat finding ? This is a repeat finding. See 2021-003. Recommendation ? We recommend the University revise its policies to establish cross-training protocols for responsibilities related to disbursement of federal aid. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters. It also enables us to communicate effectively with the accounting office and ensure disbursements and refunds are processed timely and in accordance with the Department of Education rules and regulations.
FINDING 2022-004?Special Tests and Provisions?Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "See Schedule of Findings and Questioned Costs for chart/table." Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/context ? A sample of 3 federal aid recipient students was selected from reports of students who graduated during the 2021-2022 academic year. There were no students who withdrew or dropped during the 2021-2022 academic year. The enrollment information and withdrawal or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the status change of 1 graduated student selected for testing was not reported to the NSLDS. Cause ? Due to turnover in the position responsible for performing the manual reporting process, reporting was not completed until the responsibility was assigned to a new employee. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat finding ? This is a repeat finding. See 2021-005. Recommendation ? We recommend the University revise its policies to establish cross-training protocols for responsibilities that contain strict deadlines. Views of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.