Finding 1169411 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-01-16
Audit: 382340
Organization: Life University, Inc. (GA)
Auditor: BDO USA PC

AI Summary

  • Core Issue: The University failed to notify a student borrower about their loan disbursement within the required timeframe.
  • Impacted Requirements: This oversight violates federal regulations regarding timely award notifications for Direct Loans and TEACH Grants.
  • Recommended Follow-Up: Implement procedures to ensure timely award notifications and develop a protocol for reviewing affected processes during incidents.

Finding Text

Federal Program Information: Student Financial Assistance Cluster: Federal Direct Loan Program (Assistance Listing #84.268) Criteria or Specific Requirement:N. Special Tests and Provisions – Award notification: Federal regulation 34 CFR 668.165 states if an institution credits a student ledger account with Direct Loan, Federal Perkins Loan, or TEACH Grant program funds, the institution must notify the student or parent of (i) The anticipated date and amount of the disbursement; (ii) The student's or parent's right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary; and (iii) The procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement, (3)(i) No earlier than 30 days before, and no later than 30 days after, crediting the student's ledger account at the institution, if the institution obtains affirmative confirmation from the student. Condition: The University did not send an award disbursement notification to the student borrower within the required timeframe. Cause: Administrative oversight. Effect or Possible Effect: The University was not in compliance with required federal guidelines. Questioned Costs: None. Context: Award Disbursement Notification: For 1 of 25 direct loan disbursements tested, the university did not provided timely notification to the student of (1) the date and amount of the disbursement; (2) the student's/parent's right to cancel; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel. Identification of Repeat Finding: No. Recommendation: The University should implement procedures to ensure that award notifications are reported in a timely manner. Views of Responsible Officials: Incident Response and Process Impact Assessment: •Develop a standard protocol for identifying and reviewing business processes that may be impactedduring or after a data security event. •Document any suspended or delayed processes duringan incident and report to IT and follow-up. • Conduct a post-incident reconciliation of all financial aid transactions (disbursements, notifications, adjustments) to ensure completeness and compliance. • Collaborate with IT to include critical Student Account processes in the business continuity and recovery plan, ensuring prioritized restoration after any system outage or data event.

Corrective Action Plan

Individuals Responsible for Corrective Action Plan: •Director of Student Accounts •IT Systems Administrator •CIO •Senior Director of Student Administration and Compliance Cause: The notification for this student was not generated due to timing and process gaps associated with the data security incident that occurred on July 30, 2024. The disbursement posted on Thursday, July 25, one day after the automated report selection window closed. As the team worked to assess the impact of the security incident, this process was not reviewed and this record fell outside of the reporting cycle and was not manually identified for notification. Management’s Corrective Action Plan: Incident Response and Process Impact Assessment: •Develop a standard protocol for identifying and reviewing business processes that may beimpacted during or after a data security event. •Document any suspended or delayed processes during an incident and report to IT andfollow-up. •Conduct a post-incident reconciliation of all financial aid transactions (disbursements,notifications, adjustments) to ensure completeness and compliance. •Collaborate with IT to include critical Student Account processes in the business continuityand recovery plan, ensuring prioritized restoration after any system outage or data event. Anticipated Completion Date: 2/9/2026

Categories

Student Financial Aid Special Tests & Provisions

Other Findings in this Audit

  • 1169409 2025-001
    Material Weakness Repeat
  • 1169410 2025-001
    Material Weakness Repeat
  • 1169412 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $103.46M
84.063 FEDERAL PELL GRANT PROGRAM $2.71M
84.033 FEDERAL WORK-STUDY PROGRAM $535,592
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $138,755
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $0