Finding 1181757 (2025-004)

FINDING 2025-004 Federal Program Information: Federal Direct Student Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) L. Reporting – Financial Reporting – Federal regulations, 34 CFR 690.83, require that the School submit origination records for students to the Common Origination and Disbursement (“COD”) system. Items considered key in student origination records, if applicable, are: award amount, enrollment date, verification status code (when the applicant is selected for verification), transaction number, cost of attendance, and the “Academic Start Date” and “Academic End Date”. Condition: During our testing of the Federal Direct Student Loan origination records, we noted the following exceptions: • For 7 of 25 students tested, certain key items within the students’ origination records reported to the COD did not agree to School’s supporting documentation. Cause: Insufficient administrative oversight and internal controls with respect to reporting of origination records. Effect or Potential Effect: The School is not properly following it policies and procedures in place to ensure that compliance is maintained with respect to origination record reporting. Failure to submit accurate COD origination records could result in improper awards of Direct Loans. Questioned Costs: None. Context: We tested a sample of 25 students and identified 7 exceptions as noted in the condition for which certain key items within students’ origination records reported to the COD did not agree to the School’s supporting documentation. Identification as a Repeat Finding: No similar finding was identified during the prior year. Recommendation: We recommend that the School adhere to its procedures and internal controls over the applicable compliance requirements for Federal Direct Student Loan origination records to ensure that the origination records submitted to COD match the School’s own records before file submission. Views of Responsible Officials and Planned Corrective Actions: We concur. The Registrar prepares the program calendars with input from the programs on an annual basis. MSM has a diversity of programs with different start and end dates. We understand that this needs to be accurately reflected in our calendars and in the Banner system or other enrollment platform. Academic calendars will be reviewed by the Registrar and program staff on an annual basis. Any changes to the academic calendars will need to be communicated to all members of the team. Updated calendars will be posted annually on the website and in the student handbook. After the Registrar’s Office confirms the academic start date and academic end date, Student Fiscal Affairs will continue to input this information in our Student Information System Banner to allow accuracy in our student records sent to the Department of Education Common Origination and Disbursement. If there is a change in the academic start dates and/or academic end dates, the Registrar’s Office will notify Student Fiscal Affairs, Admissions, and Student Accounts to allow for updates within the institution.