Finding 1166262 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2025-12-23
Audit: 377334
Organization: City Colleges of Chicago (IL)
Auditor: RSM US LLP

AI Summary

  • Core Issue: City Colleges failed to provide proof that direct loan disbursement notifications were sent on time to students and parents.
  • Impacted Requirements: This violates 34 CFR 668.165, which mandates timely written notifications about loan disbursements and cancellation rights.
  • Recommended Follow-Up: Improve the system to keep records of both the notification dates and the content of the notifications sent.

Finding Text

Finding 2025-001 – Direct Loan Disbursement Notifications Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Direct Student Loans: 84.268 Federal Award Year 2024-2025 Award Number: P268K Condition During our testing over direct loan disbursement notifications, we found that for twenty out of twenty students tested, City Colleges could not provide evidence that notifications were sent within the required timeframe informing the student, or parent, that a credit will be made to the student’s account for a direct loan disbursement. While City Colleges demonstrated that its system was configured to automatically send notification letters and confirmed that notifications were issued, City Colleges could not provide documentation showing the specific date each notification was sent in relation to the loan disbursement. Criteria 34 CFR 668.165 requires institutions who credit a student's account with a direct loan disbursement must notify the student, or parent, in writing of the (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 proceeds returned..; 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. 2 CFR Section 200.303 requires entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure there is a sufficient audit trail of direct loan disbursement notifications. Questioned Costs None. Cause City Colleges’ system is designed to record the date notifications are sent to students; however, it does not retain a copy of the actual notification content that was transmitted. Context Frequent. Twenty out of twenty students (100%) selected for testing. Effect Failure to maintain documentation of the notifications sent to students regarding their direct loan disbursements may prevent students from exercising their right to cancel awards within the allowable timeframe. This constitutes noncompliance with federal regulations and could jeopardize City Colleges’ eligibility for future funding. Recommendation We recommend City Colleges enhance its system to retain both the date of the notification and a copy of the actual notification sent to students. Views of responsible officials We agree with this finding. See corrective action plan.

Corrective Action Plan

Condition During our testing over direct loan disbursement notifications, we found that for twenty out of twenty students tested, City Colleges could not provide evidence that notifications were sent within the required timeframe informing the student, or parent, that a credit will be made to the student’s account for a direct loan disbursement. While City Colleges demonstrated that its system was configured to automatically send notification letters and confirmed that notifications were issued, City Colleges could not provide documentation showing the specific date each notification was sent in relation to the loan disbursement. Cause City Colleges’ system is designed to record the date notifications are sent to students; however, it does not retain a copy of the actual notification content that was transmitted. Corrective Action Taken or Planned City Colleges’ IT team, in collaboration with a consultant, will configure the system to bring all Direct Loan communication letters into the Financial Aid (FA) Status pages. Integrating these letters directly into the FA Status page will ensure they are easily accessible for FA staff. As part of this enhancement, City Colleges will be able to view a timestamp indicating when each communication was sent to the student, as well as view the information required to be communicated by 34 CFR 668.165. Contact Person: Leticia Garcia, District Director of Student Financial Aid Anticipated Completion Date: December 13, 2025

Categories

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1166261 2025-002
    Material Weakness Repeat
  • 1166263 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $77.01M
84.268 FEDERAL DIRECT STUDENT LOANS $4.65M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $1.93M
84.033 FEDERAL WORK-STUDY PROGRAM $1.47M
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $1.33M
84.042 TRIO STUDENT SUPPORT SERVICES $855,372
16.525 GRANTS TO REDUCE DOMESTIC VIOLENCE, DATING VIOLENCE, SEXUAL ASSAULT, AND STALKING ON CAMPUS $766,000
84.425 EDUCATION STABILIZATION FUND $535,466
12.006 NATIONAL DEFENSE EDUCATION PROGRAM $517,554
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $506,071
93.600 HEAD START $493,515
20.205 HIGHWAY PLANNING AND CONSTRUCTION $419,204
16.575 CRIME VICTIM ASSISTANCE $387,464
81.117 ENERGY EFFICIENCY AND RENEWABLE ENERGY INFORMATION DISSEMINATION, OUTREACH, TRAINING AND TECHNICAL ANALYSIS/ASSISTANCE $378,893
84.044 TRIO TALENT SEARCH $327,013
84.066 TRIO EDUCATIONAL OPPORTUNITY CENTERS $289,543
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $282,763
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $230,241
84.031 HIGHER EDUCATION INSTITUTIONAL AID $213,303
10.558 CHILD AND ADULT CARE FOOD PROGRAM $158,480
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $112,959
17.274 YOUTHBUILD $106,685
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $94,556
81.049 OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM $43,317
93.732 MENTAL AND BEHAVIORAL HEALTH EDUCATION AND TRAINING GRANTS $38,342
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $28,105
93.969 PPHF GERIATRIC EDUCATION CENTERS $24,676
45.162 PROMOTION OF THE HUMANITIES TEACHING AND LEARNING RESOURCES AND CURRICULUM DEVELOPMENT $18,717
93.113 ENVIRONMENTAL HEALTH $17,747
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $13,477
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $3,309