FAC Explorer

Finding 1102785 (2024-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-03-09
Audit: 345274
Organization: Saint Louis University (MO)
Auditor: Kpmg

AI Summary

  • Core Issue: The University failed to report Pell and Federal Direct Loan disbursement data accurately and within the required 15-day timeframe, leading to noncompliance with federal requirements.
  • Impacted Requirements: Reporting inaccuracies included incorrect academic end dates and student years, affecting 33% of Pell disbursements and 1% of Federal Direct Loan disbursements.
  • Recommended Follow-Up: The University should enhance internal controls and management reviews to ensure timely and accurate reporting to the Common Origination and Disbursement (COD).

Finding Text

Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, 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. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353

Categories

Matching / Level of Effort / Earmarking Student Financial Aid

Other Findings in this Audit

  • 526335 2024-001
    Material Weakness Repeat
  • 526336 2024-001
    Material Weakness Repeat
  • 526337 2024-001
    Material Weakness Repeat
  • 526338 2024-003
    Material Weakness
  • 526339 2024-003
    Material Weakness
  • 526340 2024-003
    Material Weakness
  • 526341 2024-001
    Material Weakness Repeat
  • 526342 2024-001
    Material Weakness Repeat
  • 526343 2024-001
    Material Weakness Repeat
  • 526344 2024-001
    Material Weakness Repeat
  • 526345 2024-001
    Material Weakness Repeat
  • 526346 2024-002
    Material Weakness
  • 526347 2024-002
    Material Weakness
  • 526348 2024-002
    Material Weakness
  • 526349 2024-002
    Material Weakness
  • 526350 2024-002
    Material Weakness
  • 526351 2024-003
    Material Weakness
  • 526352 2024-003
    Material Weakness
  • 526353 2024-003
    Material Weakness
  • 526354 2024-003
    Material Weakness
  • 526355 2024-003
    Material Weakness
  • 526356 2024-004
    Significant Deficiency
  • 526357 2024-004
    Significant Deficiency
  • 526358 2024-004
    Significant Deficiency
  • 526359 2024-004
    Significant Deficiency
  • 526360 2024-004
    Significant Deficiency
  • 1102777 2024-001
    Material Weakness Repeat
  • 1102778 2024-001
    Material Weakness Repeat
  • 1102779 2024-001
    Material Weakness Repeat
  • 1102780 2024-003
    Material Weakness
  • 1102781 2024-003
    Material Weakness
  • 1102782 2024-003
    Material Weakness
  • 1102783 2024-001
    Material Weakness Repeat
  • 1102784 2024-001
    Material Weakness Repeat
  • 1102786 2024-001
    Material Weakness Repeat
  • 1102787 2024-001
    Material Weakness Repeat
  • 1102788 2024-002
    Material Weakness
  • 1102789 2024-002
    Material Weakness
  • 1102790 2024-002
    Material Weakness
  • 1102791 2024-002
    Material Weakness
  • 1102792 2024-002
    Material Weakness
  • 1102793 2024-003
    Material Weakness
  • 1102794 2024-003
    Material Weakness
  • 1102795 2024-003
    Material Weakness
  • 1102796 2024-003
    Material Weakness
  • 1102797 2024-003
    Material Weakness
  • 1102798 2024-004
    Significant Deficiency
  • 1102799 2024-004
    Significant Deficiency
  • 1102800 2024-004
    Significant Deficiency
  • 1102801 2024-004
    Significant Deficiency
  • 1102802 2024-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $9.81M
84.038 Federal Perkins Loan Program_federal Capital Contributions $3.66M
93.493 Congressional Directives $2.05M
84.033 Federal Work-Study Program $1.42M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $1.20M
21.016 Equitable Sharing $913,377
93.969 Pphf Geriatric Education Centers $890,915
93.364 Nursing Student Loans $881,041
93.342 Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students $835,597
93.178 Nursing Workforce Diversity $636,629
93.264 Nurse Faculty Loan Program (nflp) $526,500
47.084 Nsf Technology, Innovation, and Partnerships $498,989
93.732 Mental and Behavioral Health Education and Training Grants $467,066
93.110 Maternal and Child Health Federal Consolidated Programs $437,203
93.396 Cancer Biology Research $427,974
84.423 Supporting Effective Educator Development Program $371,218
84.044 Trio Talent Search $284,136
84.047 Trio Upward Bound $235,214
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $224,002
12.910 Research and Technology Development $211,356
93.113 Environmental Health $210,035
12.U12 Department of Defense $190,489
12.800 Air Force Defense Research Sciences Program $163,400
45.163 Promotion of the Humanities Professional Development $138,745
93.914 Hiv Emergency Relief Project Grants $118,800
11.900 Patent and Trademark Technical Information Dissemination $110,994
93.516 Public Health Training Centers Program $107,407
47.049 Mathematical and Physical Sciences $104,340
45.169 Promotion of the Humanities Office of Digital Humanities $104,313
14.U14 Department of Housing and Urban Development $99,352
93.859 Biomedical Research and Research Training $92,620
93.867 Vision Research $88,220
43.002 Aeronautics $88,196
93.398 Cancer Research Manpower $86,172
93.121 Oral Diseases and Disorders Research $83,354
81.RD Department of Energy $82,555
10.937 Partnerships for Climate-Smart Commodities $80,243
19.345 International Programs to Support Democracy, Human Rights and Labor $77,144
10.310 Agriculture and Food Research Initiative (afri) $74,470
93.350 National Center for Advancing Translational Sciences $73,645
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $71,990
47.050 Geosciences $69,908
47.070 Computer and Information Science and Engineering $67,079
66.509 Science to Achieve Results (star) Research Program $64,197
84.268 Federal Direct Student Loans $63,024
93.134 Grants to Increase Organ Donation $59,516
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $57,763
43.008 Office of Stem Engagement (ostem) $56,196
16.602 Corrections Research and Evaluation and Policy Formulation $53,246
11.U11 Department of Commerce $53,105
93.242 Mental Health Research Grants $51,345
93.310 Trans-Nih Research Support $49,400
81.121 Nuclear Energy Research, Development and Demonstration $46,921
93.107 Area Health Education Centers $43,136
93.928 Special Projects of National Significance $38,692
19.017 Environmental and Scientific Partnerships and Programs $36,875
21.RD Department of Treasury $33,375
12.630 Basic, Applied, and Advanced Research in Science and Engineering $32,966
64.RD Department of Veterans Affairs $29,971
84.RD Department of Education $28,352
93.855 Allergy and Infectious Diseases Research $27,055
66.815 Brownfields Job Training Cooperative Agreements $25,602
47.074 Biological Sciences $25,492
81.049 Office of Science Financial Assistance Program $24,362
12.RD Department of Defense $23,875
93.173 Research Related to Deafness and Communication Disorders $23,726
43.RD National Aueronautics and Space Administration $22,063
47.075 Social, Behavioral, and Economic Sciences $20,782
93.865 Child Health and Human Development Extramural Research $19,273
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $16,897
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $16,158
93.191 Graduate Psychology Education $15,917
43.001 Science $15,904
93.394 Cancer Detection and Diagnosis Research $15,586
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $14,761
93.397 Cancer Centers Support Grants $14,670
93.839 Blood Diseases and Resources Research $14,370
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $12,735
47.076 Stem Education (formerly Education and Human Resources) $12,494
10.001 Agricultural Research Basic and Applied Research $12,476
93.994 Maternal and Child Health Services Block Grant to the States $12,285
93.395 Cancer Treatment Research $10,621
15.815 National Land Remote Sensing Education Outreach and Research $10,000
93.758 Preventive Health and Health Services Block Grant Funded Solely with Prevention and Public Health Funds (pphf) $9,642
15.805 Assistance to State Water Resources Research Institutes $9,455
10.215 Sustainable Agriculture Research and Education $8,981
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $8,201
93.837 Cardiovascular Diseases Research $8,030
93.866 Aging Research $6,060
12.114 Collaborative Research and Development $5,481
93.279 Drug Use and Addiction Research Programs $4,939
93.103 Food and Drug Administration Research $4,807
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $4,795
93.838 Lung Diseases Research $4,478
93.077 Family Smoking Prevention and Tobacco Control Act Regulatory Research $4,119
12.420 Military Medical Research and Development $4,111
93.527 Grants for New and Expanded Services Under the Health Center Program $4,047
81.135 Advanced Research Projects Agency - Energy $4,011
93.393 Cancer Cause and Prevention Research $3,648
16.601 Corrections Training and Staff Development $3,565
43.009 Mission Support $3,253
17.502 Occupational Safety and Health Susan Harwood Training Grants $2,772
93.361 Nursing Research $2,648
93.840 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $1,883
93.U93 Department of Health and Human Services $1,301
93.RD Department of Health and Human Services $902
15.807 Earthquake Hazards Program Assistance $-95
84.007 Federal Supplemental Educational Opportunity Grants $-562
12.300 Basic and Applied Scientific Research $-880
20.205 Highway Planning and Construction $-883
93.011 National Organizations for State and Local Officials $-954
84.425 Education Stabilization Fund $-4,983
47.041 Engineering $-32,634