FAC Explorer

Finding 370675 (2023-003)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-02-27
Audit: 292382
Organization: Central Michigan University (MI)
Auditor: Plante & Moran PLLC

AI Summary

  • Core Issue: The University failed to comply with disclosure requirements for Tier One and Tier Two financial arrangements.
  • Impacted Requirements: Regulations require schools to disclose contracts and cost information for financial accounts offered to students.
  • Recommended Follow-Up: Implement controls to ensure compliance with all cash management requirements and schedule regular reviews.

Finding Text

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions Cash Management Significant Deficiency

Other Findings in this Audit

  • 370657 2023-001
    Material Weakness Repeat
  • 370658 2023-002
    Material Weakness Repeat
  • 370659 2023-003
    Significant Deficiency
  • 370660 2023-004
    Significant Deficiency
  • 370661 2023-001
    Material Weakness Repeat
  • 370662 2023-002
    Material Weakness Repeat
  • 370663 2023-003
    Significant Deficiency
  • 370664 2023-004
    Significant Deficiency
  • 370665 2023-001
    Material Weakness Repeat
  • 370666 2023-002
    Material Weakness Repeat
  • 370667 2023-003
    Significant Deficiency
  • 370668 2023-004
    Significant Deficiency
  • 370669 2023-001
    Material Weakness Repeat
  • 370670 2023-002
    Material Weakness Repeat
  • 370671 2023-003
    Significant Deficiency
  • 370672 2023-004
    Significant Deficiency
  • 370673 2023-001
    Material Weakness Repeat
  • 370674 2023-002
    Material Weakness Repeat
  • 370676 2023-004
    Significant Deficiency
  • 370677 2023-001
    Material Weakness Repeat
  • 370678 2023-002
    Material Weakness Repeat
  • 370679 2023-003
    Significant Deficiency
  • 370680 2023-004
    Significant Deficiency
  • 370681 2023-001
    Material Weakness Repeat
  • 370682 2023-002
    Material Weakness Repeat
  • 370683 2023-003
    Significant Deficiency
  • 370684 2023-004
    Significant Deficiency
  • 370685 2023-001
    Material Weakness Repeat
  • 370686 2023-002
    Material Weakness Repeat
  • 370687 2023-003
    Significant Deficiency
  • 370688 2023-004
    Significant Deficiency
  • 370689 2023-001
    Material Weakness Repeat
  • 370690 2023-002
    Material Weakness Repeat
  • 370691 2023-003
    Significant Deficiency
  • 370692 2023-004
    Significant Deficiency
  • 947099 2023-001
    Material Weakness Repeat
  • 947100 2023-002
    Material Weakness Repeat
  • 947101 2023-003
    Significant Deficiency
  • 947102 2023-004
    Significant Deficiency
  • 947103 2023-001
    Material Weakness Repeat
  • 947104 2023-002
    Material Weakness Repeat
  • 947105 2023-003
    Significant Deficiency
  • 947106 2023-004
    Significant Deficiency
  • 947107 2023-001
    Material Weakness Repeat
  • 947108 2023-002
    Material Weakness Repeat
  • 947109 2023-003
    Significant Deficiency
  • 947110 2023-004
    Significant Deficiency
  • 947111 2023-001
    Material Weakness Repeat
  • 947112 2023-002
    Material Weakness Repeat
  • 947113 2023-003
    Significant Deficiency
  • 947114 2023-004
    Significant Deficiency
  • 947115 2023-001
    Material Weakness Repeat
  • 947116 2023-002
    Material Weakness Repeat
  • 947117 2023-003
    Significant Deficiency
  • 947118 2023-004
    Significant Deficiency
  • 947119 2023-001
    Material Weakness Repeat
  • 947120 2023-002
    Material Weakness Repeat
  • 947121 2023-003
    Significant Deficiency
  • 947122 2023-004
    Significant Deficiency
  • 947123 2023-001
    Material Weakness Repeat
  • 947124 2023-002
    Material Weakness Repeat
  • 947125 2023-003
    Significant Deficiency
  • 947126 2023-004
    Significant Deficiency
  • 947127 2023-001
    Material Weakness Repeat
  • 947128 2023-002
    Material Weakness Repeat
  • 947129 2023-003
    Significant Deficiency
  • 947130 2023-004
    Significant Deficiency
  • 947131 2023-001
    Material Weakness Repeat
  • 947132 2023-002
    Material Weakness Repeat
  • 947133 2023-003
    Significant Deficiency
  • 947134 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $27.96M
84.063 Federal Pell Grant Program $15.78M
84.033 Federal Work-Study Program $975,276
84.007 Federal Supplemental Educational Opportunity Grants $470,493
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $470,480
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $339,406
84.326 Special Education_technical Assistance and Dissemination to Improve Services and Results for Children with Disabilities $200,385
47.074 Biological Sciences $198,348
84.217 Trio_mcnair Post-Baccalaureate Achievement $195,671
84.044 Trio_talent Search $175,601
47.041 Engineering $171,750
12.910 Research and Technology Development $149,218
84.047 Trio_upward Bound $137,415
97.036 Covid-19 - Disaster Grants - Public Assistance (presidentially Declared Disasters) $135,284
93.310 Trans-Nih Research Support $112,859
93.866 Aging Research $91,797
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $82,118
93.575 Child Care and Development Block Grant $78,800
11.300 Investments for Public Works and Economic Development Facilities $69,375
12.RD Benchmarking Quantum Enhancement in Science & Technology $68,262
93.211 Telehealth Programs $67,387
47.075 Social, Behavioral, and Economic Sciences $61,571
93.855 Allergy, Immunology and Transplantation Research $55,721
93.493 Cmu Telehealth Services & Information Technology $46,280
15.608 Fish and Wildlife Management Assistance $46,178
93.136 Injury Prevention and Control Research and State and Community Based Programs $45,888
11.417 Sea Grant Support $42,600
47.078 Polar Programs $41,719
93.395 Cancer Treatment Research $40,425
43.001 Science $39,698
93.110 Maternal and Child Health Federal Consolidated Programs $29,643
93.732 Mental and Behavioral Health Education and Training Grants $25,000
11.609 Measurement and Engineering Research and Standards $23,069
66.708 Pollution Prevention Grants Program $23,007
10.558 Child and Adult Care Food Program $22,617
12.006 National Defense Education Program $21,727
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $19,994
93.778 Medical Assistance Program $19,714
11.459 Weather and Air Quality Research $18,709
66.469 Great Lakes Program $18,657
93.838 Lung Diseases Research $17,661
81.049 Office of Science Financial Assistance Program $17,311
93.837 Cardiovascular Diseases Research $16,717
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $16,576
15.933 Preservation of Japanese American Confinement Sites $16,122
93.859 Biomedical Research and Research Training $15,756
12.630 Basic, Applied, and Advanced Research in Science and Engineering $15,696
66.461 Regional Wetland Program Development Grants $14,761
47.079 Office of International Science and Engineering $14,370
45.310 Grants to States $13,769
15.662 Great Lakes Restoration $13,335
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $11,099
89.003 National Historical Publications and Records Grants $10,742
12.420 Military Medical Research and Development $10,118
11.467 Meteorologic and Hydrologic Modernization Development $9,938
66.951 Environmental Education Grants $9,609
93.997 Assisted Outpatient Treatment $9,581
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $9,410
47.050 Geosciences $7,923
93.173 Research Related to Deafness and Communication Disorders $7,898
15.945 Cooperative Research and Training Programs Ð Resources of the National Park System $7,573
11.432 National Oceanic and Atmospheric Administration (noaa) Cooperative Institutes $5,955
84.181 Special Education-Grants for Infants and Families $5,863
84.305 Education Research, Development and Dissemination $4,359
93.865 Child Health and Human Development Extramural Research $3,681
93.399 Cancer Control $2,500
47.076 Education and Human Resources $2,200
16.607 Bulletproof Vest Partnership Program $1,368
47.049 Mathematical and Physical Sciences $120