Finding 1310 (2023-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2023-11-07
Audit: 2445
Organization: Union College (NE)

AI Summary

  • Core Issue: The College failed to maintain proper documentation for promissory notes, impacting compliance with federal regulations.
  • Impacted Requirements: According to 34 CFR 674.16, students must sign promissory notes before receiving financial aid disbursements.
  • Recommended Follow-Up: Implement procedures to ensure all students complete promissory notes and establish a record retention system for documentation.

Finding Text

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid ALN Number: Student Financial Aid Cluster Award Period: June 01, 2022 through May 31, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 674.16 states that before an institution makes its first disbursement to a student, the student shall sign the promissory note. Condition: Perkins Promissory Note - During our testing of the Student Financial Aid Cluster, we noted that 3 students out of 65 tested in the Perkins loan program could not be supported as having completed a promissory note. Questioned Costs: None Context: Many of the missing promissory notes were old and could not be located in paper or electronic files. Cause: The College did not have a process in place to ensure promissory notes were appropriately retained either in paper or electronic format. Effect: The College cannot provide documentation showing proper completion of promissory note as required by DOE requirements. Repeat finding: No Recommendation: We recommend that the College put a procedure in place to ensure that all students have a promissory note prior to disbursing of funds. Also recommend a procedure be put in place to ensure proper record retention documenting the completion of promissory note. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Perkins Promissory Notes – Assistance Listing No. 84.038 Recommendation: We recommend that the College put a procedure in place to ensure that all students have a promissory note prior to disbursing of funds. Also recommend a procedure be put in place to ensure proper record retention documenting the completion of promissory note. View of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: The process Union College follows to ensure promissory notes are signed is coordinated through Student Financial Services (SFS). SFS determines eligibility of awards and adds them to the student financial package. Once a loan has been accepted SFS has the student sign the promissory note. The loan is disbursed once the paperwork has been completed and reviewed. Perkins loans followed this procedure in the time they were available. The Perkins program is no longer active so there are no new promissory notes going forward. Student accounts is currently reviewing student files to ensure promissory notes, or documentation deemed appropriate by the Department of Education, are available for the Perkins loans that will be assigned to the Department of Education. Unfortunately, previous employees did not keep accurate records; this was brought to light when a new employee took over student accounts in August 2021. While the new employee has worked hard to track down all MPNs, we know that there are some that will never be found. As a result, this will likely be a repeat finding until all Perkins Loans are assigned or liquidated. It is our hope that this process will be completed by May 31, 2025. Promissory notes or documentation will be retained until the loans are either assigned or liquidated. Name(s) of the contact person(s) responsible for corrective action: Steve Trana, VP for Financial Administration Planned completion date for corrective action plan: We hope to assign or liquidate all Perkins loans by May 31, 2025. Until then, it is likely that this will be a recurring item on our corrective action report.

Categories

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

Other Findings in this Audit

  • 1311 2023-002
    Significant Deficiency
  • 1312 2023-003
    Significant Deficiency
  • 577752 2023-002
    Significant Deficiency
  • 577753 2023-002
    Significant Deficiency
  • 577754 2023-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $6.44M
84.063 Federal Pell Grant Program $1.07M
84.038 Federal Perkins Loan Program - Beginning Balance $909,201
93.364 Nursing Student Loans $263,182
84.033 Federal Work-Study Program $145,190
84.007 Federal Supplemental Educational Opportunity Grants $138,396
84.038 Federal Perkins Loan Program - Loans Issued $0