Finding Text
Assistance Listing Number, Federal Agency, and Program Name - 84.033, 84.038, 84.268; U.S. Department of Education; Student Financial Assistance Cluster
Federal Award Identification Number and Year - June 1, 2023 to May 31, 2024
Pass through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2021-006, 2022-004, 2023-004
Criteria - Institutions of higher education are required to submit a Fiscal Operations Report and Application to Participate (FISAP) to the U.S. Department of Education. This electronic report is submitted annually to receive funds for the campus based programs. The School uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year.
Condition - The School submitted a FISAP to the U.S. Department of Education that reported inaccurate information in several data fields within the report. In addition, there was no evidence that an individual other than the preparer reviewed the report.
Questioned Costs - None
If Questioned Costs are not Determinable, Description of Why Known Questioned Costs were Undetermined or Otherwise could not be Reported - Finding relates to inaccurate information included in the FISAP, which does not impact award amounts.
Identification of How Questioned Costs Were Computed - N/A
Context - During our testing, we noted inaccurate information in data field Part II, Section D (Information for Enrollment), Line 7b: The School reported 150 graduates enrolled for fiscal year 2022 2023. This figure did not agree to supporting documentation, and management determined that the number reported was based on the unduplicated graduate count for fall 2022. Management noted that the number that should have been reported for the 2022 2023 school year was 209.
Management also noted that there was not a formal and documented review process of the FISAP report by someone other than the preparer.
Cause and Effect - The School did not have a control in place to ensure that accurate information was submitted to the U.S. Department of Education in the FISAP report.
Submission of inaccurate information in the FISAP report may result in noncompliance with federal regulations and inaccurate awarding of federal student financial assistance amounts in subsequent fiscal years.
Recommendation - We recommend the School implement a reconciliation and review control where an individual with sufficient student financial assistance and financial understanding reviews the FISAP report to underlying institutional information to ensure accurate information is submitted with the FISAP report. Evidence of such a review and documentation supporting information reported in the FISAP should be documented and maintained.
Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. Preparation and submission of the FISAP will be completed with coordination between the VP of business and the third party processor. This includes a quality review process for accuracy.