Finding Text
A. Internal Control Findings Finding 2025-001: Material Weakness in Internal Control Over Compliance and Scope Limitation Over Special Tests and Provisions (Special Tests and Provisions) Criteria The Uniform Guidance requires the auditor to obtain sufficient appropriate audit evidence to support an opinion on whether the auditee complied with the types of compliance requirements that could have a direct and material effect on each major federal program. For the Federal Family Education Loans (Lenders) Program, ALN 84.032L, the direct and material compliance requirements identified for audit were Reporting and Special Tests and Provisions. The Special Tests and Provisions requirements applicable to the FFEL Program require the auditee to maintain sufficient borrower-level, loan-level, and system-generated documentation to demonstrate compliance with applicable program requirements and to support audit procedures. Condition The Authority was unable to provide sufficient documentation and system data necessary for us to perform required audit procedures over certain Special Tests and Provisions applicable to the Federal Family Education Loans (Lenders) Program, ALN 84.032L. Specifically, support was not available for seven of the ten Special Tests and Provisions selected or required for testing. Because the required documentation and system data were not available, we were unable to obtain sufficient appropriate audit evidence to determine whether the Authority complied with the Special Tests and Provisions compliance requirement for the FFEL Program for the year ended June 30, 2025. The Reporting compliance requirement was tested without exception. A. Internal Control Findings (Cont’d) Cause During the year, the Authority transitioned loan servicing to a third-party servicer, Higher Education Servicing Corporation (HESC). For loans issued and processed prior to the transition, servicing activity was processed under the legacy servicing system. Following the transition, the Authority no longer had access to the legacy system that maintained the portfolio documentation and related loan/system data needed to support audit procedures. Subsequently, the Authority sold or transferred its related loan portfolio. As a result of the servicing transition, loss of access to the legacy system, and sale or transfer of the related loan portfolio, certain supporting documentation and system data previously maintained for the FFEL Program were no longer available. Effect or Potential Effect Because the required servicing system data and borrower-level records were unavailable, we were unable to obtain sufficient appropriate audit evidence over Special Tests and Provisions. Accordingly, our report on compliance includes a disclaimer of opinion on the Authority’s compliance with the Special Tests and Provisions compliance requirement for the Federal Family Education Loans (Lenders) Program, ALN 84.032L. The inability to test Special Tests and Provisions also creates the potential that noncompliance with federal statutes, regulations, and the terms and conditions of the federal award could have occurred and not been detected. The Authority’s failure to retain, or otherwise maintain access to, the borrower-level and systemgenerated records necessary to support compliance with Special Tests and Provisions after the servicing transition, system decommissioning, and portfolio transfer represents a material weakness in internal control over compliance for the FFEL Program. Questioned Costs $0 identified. No questioned costs were identified from the procedures performed. However, because sufficient supporting documentation and system data were unavailable, additional questioned costs, if any, could not be determined. A. Internal Control Findings (Cont’d) Context The Federal Family Education Loans (Lenders) Program, ALN 84.032L, was identified as a major program for the year ended June 30, 2025. The direct and material compliance requirements subject to audit were Reporting and Special Tests and Provisions. Reporting was tested without exception. For Special Tests and Provisions, support was unavailable for seven of the ten requirements, resulting in a scope limitation over that compliance requirement. Recommendation We recommend that the Authority establish and maintain procedures to ensure that records supporting compliance with federal program requirements are retained and accessible for the period required by applicable federal statutes, regulations, award terms, and audit requirements. Such procedures should address system decommissioning, portfolio transfers, vendor transitions, and data retention requirements before access to legacy systems is terminated. Views of Responsible Officials Management acknowledges that sufficient documentation was not available to support all audit requirements and agrees with the recommendation. The circumstances described in this finding resulted from the transition of FFEL Program loan servicing to Higher Education Servicing Corporation (HESC) and the subsequent sale of the FFEL loan portfolio to Kentucky Higher Education Student Loan Corporation (KHESLC). Although OSLA transferred borrower-level history and transaction data to the new servicing system, access to the legacy system was discontinued, eliminating access to certain detailed records needed to support portions of the compliance testing. Because the Authority no longer owns or services the FFEL portfolio, the specific circumstances that led to this finding are not expected to recur. Nonetheless, management has implemented enhanced records management controls to help ensure the retention and accessibility of supporting documentation and to mitigate similar risks in the future.