Finding Text
Assistance Listing Number, Federal Agency, and Program Name 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program Federal Award Identification Number and Year June 1, 2024 to May 31, 2025 Pass through Entity N/A Finding Type Significant deficiency and material noncompliance with laws and regulations Repeat Finding Yes 2021 011, 2022 007, 2023 007, 2024 004 Criteria In accordance with 34 CFR 685.300(b)(9) and electronic announcement November 13, 2013, Direct Loan Quality Assurance Requirement Reminder, institutions of higher education are requested to document a Direct Loan quality assurance program. Condition The School did not have a documented Direct Loan quality assurance program in place during a significant portion of the year under audit. 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 a policy not in place, which would not impact award amounts. Identification of How Questioned Costs Were Computed N/A Context During our testing, management stated that the School implemented its Direct Loan quality assurance program in March 2025; therefore, the policy was not in place during a significant portion of the year. Cause and Effect During a significant portion of the year, the School did not have a policy in place to ensure that its Direct Loan quality assurance efforts are documented in accordance with federal regulations. Recommendation We recommend the School establish the required Direct Loan quality assurance program and that contemporaneous evidence of consistent adherence to such a program be maintained. Views of Responsible Officials and Corrective Action Plan 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. The School coordinated with this third party processor to ensure that a documented quality assurance program was put into place in March 2025 and regularly exercised for compliance purposes. All documentation will be maintained.