Finding 25515 (2022-001)

- Repeat Finding
Requirement
E
Questioned Costs
$1
Year
2022
Accepted
2022-11-09
Audit: 25905
Organization: Millikin University (IL)
Auditor: Sikich LLP

AI Summary

  • Core Issue: Three out of 40 student files (7.5%) had errors in awarding Subsidized and Unsubsidized Direct loans, leading to under and over awards.
  • Impacted Requirements: Noncompliance with eligibility criteria for Title IV aid, specifically regarding the order of aid disbursement as outlined in federal regulations.
  • Recommended Follow-Up: The University should review and improve its policies and procedures to ensure accurate awarding of Title IV aid to students.

Finding Text

2022-001 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 Criteria: 34 CFR 685.101 (b)(1) notes, ?an eligible undergraduate student who is enrolled at a school participating in the Direct Loan Program may borrow under the Direct Subsidized Loan and Direct Unsubsidized Loan programs.? The order of dispersing aid requires that grants and subsidized loans be considered first. 34 CFR 685.200(a)(iii) ?In the case of an undergraduate student who seeks a Direct Subsidized Loan or a Direct Unsubsidized Loan at a school that participates in the Federal Pell Grant Program, the student has received a determination of Federal Pell Grant eligibility for the period of enrollment for which the loan is sought.? Condition: In three of the 40 student files tested (7.5%), Subsidized and Unsubsidized Direct loans we not properly awarded. The University under awarded one student $1,000 in Subsidized loans and over awarded the student by $1,000 in Unsubsidized loans. A second student was under awarded $2,560 in Subsidized loans and over awarded $2,560 in Unsubsidized loans. The third student was under awarded $862 in Unsubsidized loans. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and a repeat of prior year finding 2021-002. Statistical sampling was not used in making sample selections. Questioned Costs: $862 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Students should receive the proper amount of aid. Recommendation: We recommend the University evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan. See chart/table in report

Corrective Action Plan

2022-001 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 Condition: In three of the 40 student files tested (7.5%), Subsidized and Unsubsidized Direct loans were not properly awarded. The University under awarded one student $1,000 in Subsidized loans and over awarded the student by $1,000 in Subsidized loans. A second student was under awarded $2,560 in Subsidized loans and over awarded $2,560 in Unsubsidized loans. The third student was under awarded $862 in Unsubsidized loans. Management Response: All of the errors identified by the auditors were a direct result of manual miscalculation of loan eligibility. In two of the instances cited, the students had previous additional unsubsidized loans issued as a result of parent PLUS loan denials. When we received ISIR data these students were flagged with a reject due to aggregate loan limits. In order to calculate each student?s loan eligibility, a manual review of loan information via the U.S. Department of Education?s Common Origination and Disbursement (COD) portal is necessary. The additional unsubsidized loans disbursed as a result of PLUS denial, were manually removed from each student?s loan total to determine current year eligibility. In both instances, the total loan eligibility was correct, however the manual calculation of the subsidized versus unsubsidized split of the loan funds were miscalculated. In the last instance a student was under awarded $862 in unsubsidized loans, the miscalculation occurred due to receipt of an outside scholarship. In the Fall term the scholarship check was received with documentation indicating the disbursement was to be applied to the Fall term in it?s entirety and the Spring disbursement would follow. The outside scholarship caused the student to be over awarded and the student loans were adjusted to remain within cost of attendance limits. Subsequently the Spring term disbursement of the scholarship was received for $862 less than the Fall disbursement. At that time, the student should have been offered the additional $862 in unsubsidized loan funds to bring their total aid back up to cost of attendance. The staff person entering the scholarship payment on the student?s account failed to notify the loan coordinator an adjustment was warranted. Corrective Action Plan: The loan coordinator who made the errors has been in the position for just over a year. In order to prevent future issues in calculating a student?s loan limits and eligibility, the employee attended a loan regulation and processing overview course produced by the National Association of Financial Aid Administrators (NASFAA). Further, a form was developed to help calculate aggregate limits when an ISIR reject occurs in order to avoid missed steps in the calculation process. 2022-001 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 (Continued) As a result of the outside scholarship error, our procedures for entering an scholarship payment have been adjusted to include a final review of all outside scholarship disbursements entered by the loan coordinator. Responsible Person: Lynette Lambert, Assistant Director/Loan Coordinator Implementation Date: August 1, 2022

Categories

Questioned Costs Student Financial Aid Eligibility Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $13.72M
84.425 Education Stabilization Fund $3.10M
84.063 Federal Pell Grant Program $3.10M
84.038 Federal Perkins Loan Program $1.97M
84.033 Federal Work-Study Program $286,373
84.007 Federal Supplemental Educational Opportunity Grants $206,342
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $19,945
45.025 Promotion of the Arts_partnership Agreements $5,500