Finding 1158189 (2024-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-09-30
Audit: 370096
Organization: Atrium Health, Inc. (NC)

AI Summary

  • Core Issue: Atrium Health CMHA failed to notify students about Direct Loan disbursements as required, with missing notification letters and untimely disbursements.
  • Impacted Requirements: Non-compliance with federal regulations under Title 2 U.S. Code and 34 CFR regarding disbursement notifications and internal controls.
  • Recommended Follow-up: Implement internal controls to ensure retention of disbursement notification letters and improve IT systems for compliance.

Finding Text

Finding 2024-003: Notification of Disbursements to or on Behalf of StudentsIdentification of the federal program: Federal Agency: United States Department of Education. Federal Cluster: Student Financial Assistance Cluster. Assistance Listing No.: 84.268 Federal Direct Student Loans (Direct Loans), 84.063 Federal Pell Grant Program, 84.007 Federal Supplemental Education Opportunity Grant Program. Award Periods: July 1, 2023 through June 30, 2024; July 1, 2024 through June 30, 2025. Criteria or specific requirement (including statutory, regulatory or other citation):Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control:“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).”34 CFR 668.165(a)(1) – Before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Condition:When Direct Loans are being credited to a student’s account, an institution must notify the student, or parent, in writing of (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. Atrium Health CMHA was unable to provide the notification letters sent to the student as they are not maintained. Further, there were three instances where student disbursements were not made timely and one instance where a disbursement resulted in a credit that was not returned timely. Cause:The current IT system does not allow for the letters sent to be saved.Effect or potential effect: The disbursement notification letters may not have be sent in accordance with the regulations.Questioned costs:None.Context:Total expenditures for the Student Financial Assistance Cluster were $2,876,252 for the year ended December 31, 2024. We selected a sample of 40 disbursements and identified 33 that did not have notification of disbursement and one disbursement that resulted in a credit that was not refunded within the time frame.Identification as a repeat finding, if applicable:This finding is a repeat finding of 2023-004 from the prior year. Recommendation:Atrium Health CMHA should implement internal controls to retain all disbursement notification letters sent to students.Views of responsible officials:Atrium Health CMHA management, as part of the 2025 process and procedures consulting engagement, will develop a plan to ensure that the IT systems are changed such that notification letters can be retained or a control exists whereby hard-copies of notification letters are maintained.

Corrective Action Plan

Corrective Action Plan: Atrium Health CMHA management, as part of the 2025 process and procedure consulting engagement, will develop a plan to ensure that the IT systems are changed such that notification letters can be retained, or a control exists whereby hard-copies of notification letters are maintained. Proposed Completion Date: By December of 2025, Atrium Health CMHA management will complete the corrective action.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1158177 2024-001
    Material Weakness Repeat
  • 1158178 2024-002
    Material Weakness Repeat
  • 1158179 2024-003
    Material Weakness Repeat
  • 1158180 2024-004
    Material Weakness Repeat
  • 1158181 2024-005
    Material Weakness Repeat
  • 1158182 2024-001
    Material Weakness Repeat
  • 1158183 2024-002
    Material Weakness Repeat
  • 1158184 2024-003
    Material Weakness Repeat
  • 1158185 2024-004
    Material Weakness Repeat
  • 1158186 2024-005
    Material Weakness Repeat
  • 1158187 2024-001
    Material Weakness Repeat
  • 1158188 2024-002
    Material Weakness Repeat
  • 1158190 2024-004
    Material Weakness Repeat
  • 1158191 2024-005
    Material Weakness Repeat
  • 1158192 2024-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $257.94M
84.268 Federal Direct Student Loans $2.11M
84.063 Federal Pell Grant Program $736,444
93.253 Poison Center Support and Enhancement Grant $504,792
21.027 Coronavirus State and Local Fiscal Recovery Funds $429,221
93.958 Block Grants for Community Mental Health Services $373,139
93.078 Strengthening Emergency Care Delivery in the United States Healthcare System Through Health Information and Promotion $253,881
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $239,599
12.420 Military Medical Research and Development $189,991
93.839 Blood Diseases and Resources Research $182,439
93.069 Public Health Emergency Preparedness $154,980
93.788 Opioid Str $116,081
16.575 Crime Victim Assistance $109,282
93.994 Maternal and Child Health Services Block Grant to the States $100,610
93.866 Aging Research $92,805
93.173 Research Related to Deafness and Communication Disorders $89,163
93.669 Child Abuse and Neglect State Grants $86,338
20.600 State and Community Highway Safety $68,610
93.RD4 Asymptomatic Cmv $58,130
93.855 Allergy, Immunology and Transplantation Research $54,000
93.837 Cardiovascular Diseases Research $51,600
14.250 Rural Housing and Economic Development $48,000
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $36,125
10.310 Agriculture and Food Research Initiative (afri) $32,756
93.361 Nursing Research $32,240
93.RD5 Research on Viral Infections $29,234
93.273 Alcohol Research Programs $27,437
84.007 Federal Supplemental Educational Opportunity Grants $27,182
93.310 Trans-Nih Research Support $20,470
93.073 Birth Defects and Developmental Disabilities - Prevention and Surveillance $20,000
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $15,600
93.838 Lung Diseases Research $9,300
93.RD6 Gateway for Cancer Research: T2016-002 $8,100
93.889 National Bioterrorism Hospital Preparedness Program $8,093
93.RD2 Chop_cog_agct1531 $7,400
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $7,147
93.RD3 Ecog-Acrin Ea4151 $5,550
12.420 Novel Topical Antibiotic Therapy to Reduce Infection After Operative Treatment of Fracturesat High Risk of Infection: Tobra -A Multicenter Randomized, Controlled Trial $5,350
93.394 Cancer Detection and Diagnosis Research $4,991
12.420 Evaluation of the Diagnostic and Therapeutic Value of Tissue Ultrafiltration in Patients at Risk of Acs $4,578
16.753 Congressionally Recommended Awards $3,885
93.110 Maternal and Child Health Federal Consolidated Programs $3,813
93.395 Cancer Treatment Research $2,940
93.399 Cancer Control $2,800
93.226 Research on Healthcare Costs, Quality and Outcomes $2,644
93.145 Aids Education and Training Centers $1,933
93.RD1 Alliance A011202 $900
93.558 Temporary Assistance for Needy Families $-186
93.121 Oral Diseases and Disorders Research $-394
16.758 Improving the Investigation and Prosecution of Child Abuse and the Regional and Local Children's Advocacy Centers $-1,800
93.840 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $-2,565
93.865 Child Health and Human Development Extramural Research $-3,172
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $-6,584
93.360 Biomedical Advanced Research and Development Authority (barda), Biodefense Medical Countermeasure Development $-13,481
93.137 Community Programs to Improve Minority Health Grant Program $-25,698