Finding 15869 (2022-002)

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Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-02
Audit: 19033
Organization: Simmons University (MA)

AI Summary

  • Core Issue: The University failed to perform a required SAS reconciliation for September 2021, violating federal regulations.
  • Impacted Requirements: Monthly reconciliation of institutional records with Direct Loan funds is mandated by 34 CFR 685.300(b)(5).
  • Recommended Follow-Up: Implement a second level of review to ensure timely preparation and review of SAS reconciliations.

Finding Text

2022-002 Borrower data and reconciliation reporting Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Number: 84.268 Criteria 34 CFR 685.300(b)(5): In the program participation agreement, the school must promise to comply with the Act and applicable regulations and must agree to - On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Condition Through our testing of 3 Student Account Statement (SAS) reconciliations, we noted 1 instance where the SAS reconciliation was not performed. Cause The University did not have sufficient oversight over the personnel who was performing the SAS reconciliations from the summer leading up to the 2021-2022 academic year through March 2022. As a result, the September 2021 disbursements were not reconciled and the University did not have the appropriate controls in place to identify that the reconciliation was not performed. Effect Without the appropriate reconciliation of direct loan disbursements, the University has an increased risk that federal funding disbursed will not be effectively managed and expended in accordance with the terms and conditions of its agreement with the federal agency. Questioned Costs None identified. Recommendation We recommend that the University implement a second level of review to ensure that SAS reconciliations are prepared and reviewed on a timely basis. Management?s Views and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary schedule of prior audit findings and status.

Corrective Action Plan

Management?s Views and Corrective Action Plan The University implemented two new systems (Student Information System ? Workday, and Financial Aid System ? PowerFaids) that each are an important part of managing our Federal Student Aid. Most of the building and configuring of these systems happened prior to FY22 with the full launch in production taking place for the Fall 2021. Understandably, some of the integrations of these two systems were not able to be tested prior to Fall of 2021 (ex: actual disbursement of federal loans) and therefore, required significant time and effort in the Fall and beyond to ensure everything worked and students were able to receive funding while also building out and documenting required communications, processes, and compliance protocols. Additionally, we had turnover within the Associate Director of Financial Aid and Loan Manager role in March 2022. The implementation coupled with this staffing issue created a one-time set of circumstances that are outside of the standard oversight and management of our Federal Student Aid funds and processes. Please refer to the response to each individual finding as follows: Finding 2022-002: Borrower data and reconciliation reporting Award Information Cluster: Student Financial Assistance Agency: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Number: 84.268 As mentioned above, the University implemented two brand new systems (Student Information System ? Workday, and Financial Aid System ? PowerFaids) that each are an important part of managing our Federal Student Aid. During the first month of the Fall term there were significant challenges with the communication between these systems, which resulted in our first group of loans being disbursed in the last few days of September 29, 2021. It is a known issue that any loans that disburse at the end of the month are not included in the Federal SAS Reconciliation file and as a result this disbursement resulted in significant errors. Ultimately, the University was not able to finalize this reconciliation for this month. As mentioned above, the Financial Aid Office was restructured to provide even greater oversight over our Federal funds. Under the restructured office, the new Associate Director and Manager of Loans and Pell Grants has documented all processes, including reconciliation. Additionally, we created an automated report that is generated after the SAS is received and loaded into PowerFaids. A notification is sent to both the Associate Director/Loan Manager as well as the Director of Financial Aid Systems, Reporting and Compliance to provide documentation that the report was run. The Loan Manager reports to the Director of Financial Aid Systems, Reporting and Compliance who signs the completed SAS reconciliations. This process was fully put into place, including signature, for the 2022-2023 academic year beginning with the September 2022 Reconciliation. The Director of Financial Aid Systems, Reporting and Compliance, Amanda Galban, who can be reached at amanda.galban@simmons.edu, is responsible for the implementation of this corrective action plan.

Categories

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

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $80.90M
84.425 Education Stabilization Fund $2.71M
84.063 Federal Pell Grant Program $2.59M
84.038 Federal Perkins Loan Program $990,570
84.033 Federal Work-Study Program $665,770
93.732 Mental and Behavioral Health Education and Training Grants $405,287
84.007 Federal Supplemental Educational Opportunity Grants $378,212
97.088 Disaster Assistance Projects $105,252
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $94,138
94.006 Americorps State and National $86,822
45.313 Laura Bush 21st Century Librarian Program $59,637
19.021 Investing in People in the Middle East and North Africa $48,933
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research - Washington University in St. Louis $46,392
47.075 Social, Behavioral, and Economic Sciences $42,898
45.312 National Leadership Grants $33,994
47.074 Biological Sciences $31,295
93.866 Aging Research $21,447
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $942