Finding 1726 (2023-001)

- Repeat Finding
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2023-11-13
Audit: 2989
Organization: East Texas Baptist University (TX)
Auditor: Capincrouse LLP

AI Summary

  • Core Issue: Two students were under awarded subsidized loans due to system limitations that failed to update need analysis after changes.
  • Impacted Requirements: This finding violates 34 CFR 685.203 regarding proper awarding of financial aid based on need.
  • Recommended Follow-Up: The University should automate the aid packaging process to minimize errors, especially as they transition to a new financial aid system for the upcoming award year.

Finding Text

Need Analysis DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Award Year Condition: Students were not appropriately awarded subsidized aid based on need when there were changes after the initial award. Criteria: 34 CFR 685.203 Questioned Costs: $-0- Context: 2 students out of 60 were under awarded subsidized loans for a total of $1,440 underawarded. These students were corrected during the audit process by reallocating unsubsidized loans to subsidized loans. Cause: The University uses a system that does not automatically update all need analysis when a subsequent change is made. One student changed the enrollment status which changed the institutional aid and resulted in more subsidized eligibility. One student went into the portal and reduced the acceptance of the subsidized loan, and this student was not flagged to automatically swap to the unsubsidized loan to subsidized loan. Effect: Incorrect allocation of subsidized versus unsubsidized which affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: Yes, 2022-001 and 2021-002. Recommendation: We recommend the University adjust processes to automate changes in packaging to reduce manual errors. We understand the University is moving to a new financial aid system for the 2023-2024 award year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Need Analysis Planned Corrective Action: ETBU financial aid staff have used a Jenzabar PX product for over 20 years. Within that product, there is no built-in compliance to assist with awarding and managing Federal Direct Loan awarding amounts based on need. The initial Federal Direct Loans were awarded correctly based on student need eligibility. However, when scholarships were added/removed or aid was adjusted based on enrollment status after origination, manual adjustments to loans are required. As a result of previous finding, ETBU implemented processes where Direct Subsidized Loans were over awarded when scholarships were added after initial packaging and eliminated all finding related to Need Analysis in 2022-2023. However, the quality assurance checks were not written to check for reduction of scholarships that might result in an under award of Direct Subsidized Loans. ETBU has a log file to document that the student elected to reduce their subsidized loan which was determined to be a finding. After further review of regulations, ETBU financial aid was only honoring the student request. ETBU financial aid office added this quality assurance check to their procedures and has conducted a 100% check for all Federal Direct Student loans for the 2022- 23 award year for over awards as well as under awarding of all Direct Loans. ETBU financial aid has implemented a new administrative software, Jenzabar Financial Aid (JFA) for the 2023-24 financial aid year. JFA has built in Federal Direct Loan packaging that checks need at the time of awarding, as well as, evaluating need when awards are changed. Additionally, quality assurance processes have been written in the new software to double check Federal Direct Loan award amounts after any funding movement on student accounts. These processes are completed before any loan disbursements to assure that compliance is maintained. Person Responsible for Corrective Action Plan: Linda Slawson, Director Financial Aid Anticipated Date of Completion: Completed

Categories

Allowable Costs / Cost Principles Eligibility Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $9.93M
84.063 Federal Pell Grant Program $2.61M
84.033 Federal Work-Study Program $129,972
84.007 Federal Supplemental Educational Opportunity Grants $116,494
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $11,316