FAC Explorer

Finding 371142 (2023-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-02-28
Audit: 292763
Organization: Our Lady of the Lake University of San Antonio (TX)
Auditor: Forvis

AI Summary

  • Core Issue: The University did not complete required monthly direct loan reconciliations for the 2022–2023 aid year.
  • Impacted Requirements: Monthly reconciliations to the Department of Education's system were not performed, risking undetected errors in direct loans.
  • Recommended Follow-Up: Implement controls to ensure monthly reconciliations are completed; a corrective action plan is in progress with a target completion date of February 15, 2024.

Finding Text

Federal Program – Student Financial Assistance Cluster Assistance Listing No. 84.268 U.S. Department of Education Program Year 2022–2023 Criteria or Specific Requirement – Direct Loan Reconciliation CFR 685.300 Condition – The University’s failed to complete required direct loan reconciliations during the 2022–2023 aid year. The University is responsible for reconcilng University disbursement data to the Department of Education’s Common Origination and Disbursement System on a monthly basis and for establishing internal controls to ensure that such reconciliations are completed within federal requirements. Questioned Costs – N/A Context – Out of a population of 12 months, two months were selected for testing. No support for the monthly reconcilations for these months was able to be provided, and it was noted that reconcilations did not take place for any months during the year ended May 31, 2023. Our sample was not, and was not intended to be, statistically valid. Effect – The University failed to complete monthly reconcilations as required and could have had errors in direct loans that were not identified. Cause – The University experienced turnover and decreased staffing levels during the year. Identification as a Repeat Finding, if Applicable – N/A Recommendation – The University should put controls in place to ensure that reconcilations are being completed on a monthly basis as required. Corrective Action Plan – OLLU has already begun coordinating processes between its Accounting and Financial Aid departments to download the monthly SAS into the University’s system electronically, where Accounting will then reconcile the statement monthly as part of its month-end close procedures. The Financial Aid Director will be responsible for ensuring that the statement is downloaded monthly as a part of the regular electronic data file transfer between OLLU and the Department of Education. The Senior Accountant in the Accounting Department will generate the report in Colleague via the DRSS process and reconcile the SAS statement to cash records. The Director of Accounting and Reporting will review the reconciliation monthly. Anticipated Completion Date – February 15, 2024

Corrective Action Plan

Our Lady of the Lake University of San Antonio FY 2023 Single Financial Audit Finding Response Corrective Action Plan – Reconciliation of COD Monthly School Account Statement Compliance Finding: The Department of Education’s (DoE) School Account Statement (SAS), downloaded electronically from the Common Origination Destination (COD) website, was not being reconciling monthly as required by the Student Financial Aid/ Direct Loan Program. Criteria or Specific Requirement: Per the Student Financial Aid/ Direct Loan Program requirements with the DoE, every school is required to reconcile their SAS to their accounting system records at least monthly. This statement is issued to each participating school through the SAIG mailbox monthly. The auditors noted 34 CFR 685.102(b), 385.300(b), 685.301, and 303 as the compliance regulation. Cause of Noncompliance: It appears that the SAS was reconciled monthly per the compliance requirement in recent years, but with high turnover and periods of under-staffing in the Accounting department this procedure was changed to one that did not meet the above requirement. Although OLLU did regularly reconcile the accounting system records with reports from COD, it was not the official monthly SAS statement. OLLU’s modified procedures did not completely meet the compliance requirement but did offer some mitigating procedures. Institution Response: OLLU has already begun coordinating processes between its Accounting and Financial Aid departments to download the monthly SAS into the university’s system electronically, where Accounting will then reconcile the statement monthly as a part of its month-end close procedures. The Financial Aid Director will be responsible for ensuring that the statement is downloaded monthly as a part of the regular electronic data file transfer between OLLU and the Department of Education. The Senior Accountant in the Accounting department will generate the report in Colleague via the DRSS process and reconcile the SAS statement to cash records. The Director of Accounting and Reporting will review the reconciliation monthly.

Categories

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

Other Findings in this Audit

  • 947584 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $24.60M
84.063 Federal Pell Grant Program $3.73M
84.038 Federal Perkins Loan Program $1.10M
84.033 Federal Work-Study Program $661,404
84.007 Federal Supplemental Educational Opportunity Grants $292,750
84.217 Trio_mcnair Post-Baccalaureate Achievement $223,625
84.425 Education Stabilization Fund $209,853
84.031 Higher Education_institutional Aid $157,114
47.076 Education and Human Resources $88,122
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $55,104
10.223 Hispanic Serving Institutions Education Grants $25,257
11.028 Connecting Minority Communities Pilot Program $16,955
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $14,121
16.575 Crime Victim Assistance $7,577
45.162 Promotion of the Humanities_teaching and Learning Resources and Curriculum Development $2,873
93.318 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security $276