Finding 371187 (2023-001)

Material Weakness
Requirement
E
Questioned Costs
$1
Year
2023
Accepted
2024-02-29
Audit: 292837
Auditor: Rsm US LLP

AI Summary

  • Core Issue: KHSC overawarded Unsubsidized Federal Direct Loans to all 61 students, exceeding the maximum allowed amount for a 10-month program by $4,445 per student.
  • Impacted Requirements: Noncompliance with federal regulations (34 CFR 685.203) regarding loan limits for graduate students, leading to a total questioned cost of $271,146.
  • Recommended Follow-Up: Strengthen internal controls to ensure proper financial aid award limits are established and adhered to in the future.

Finding Text

Finding 2023-001: Eligibility – Determining Federal Direct Student Loan Awards Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster, Federal Direct Student Loans Assistance Listing Number: 84.268 Award Year: June 1, 2022 – May 31, 2023 Program Expenditures: $5,056,223 Questioned Costs: $271,146 Criteria: Per 34 CFR 685.203(b)(iii), in the case of a graduate or professional student for a period of enrollment beginning on or after July 1, 2012, the total amount the student may borrow for any academic year of study under the Unsubsidized Loan program may not exceed $8,500. Per 34 CFR 685.203(c)(2)(v), the additional amount that a student described in paragraph (c)(1)(i) of this section may borrow under the Direct Unsubsidized Loan Program for any academic year of student may not exceed the following: in the case of a graduate or professional student, $12,000. Per the 2022-2023 Federal Student Aid Handbook, Volume 3, Chapter 5, students in Health Professions Programs, including the Doctor of Osteopathic Medicine, an additional $26,667 in Unsubsidized Loans for an Academic Year Covering 12 months can be provided to students. For programs with an academic year covering 10 or 11 months, the annual additional unsubsidized loan limit must be prorated. KHSC's program is a 10 month program and the additional limit is $22,222 for a total maximum award of $42,722. Condition: During testing of eligibility, 7 out 7 students selected for testing were overawarded Unsubsidized Federal Direct Loans. We determined that KHSC improperly awarded 61 out of 61 students Unsubsidized Federal Direct Loans in excess of the maximum amount for one academic year. KHSC overawarded each student $4,445, which accumulated to $271,146 in total loan funds overawarded. Cause: The students were overawarded as a result of the students being awarded on a 12-month program and were not properly pro-rated for the 10-month program length. Effect: KHSC is required to return overawarded funds to the Department of Education in accordance with Department guidelines. Noncompliance with federal guidelines could impact future funding. Questioned Costs: $271,146 Context: 7 out 7 students subject to eligibility testing were overawarded Unsubsidized Federal Direct Loans in excess of the maximum allowed amount of $42,722 for a 10-month program. 61 out of a total student population of 61 students were overawarded Unsubsidized Federal Direct Student Loans in excess of maximum allowed amount of $42,722. Management detected the overaward subsequent to year-end, but prior to the start of the audit and informed RSM of the error. Repeat Finding: No Recommendation: We recommend KHSC strengthen internal controls around the establishing of financial aid award limits. Views of Responsible Officials: Management agrees with the finding. Please see corrective action plan attached.

Corrective Action Plan

Over Award Review and Correction Action Taken – Kansas Health Science Center (KHSC) Identifying Number: 2023-001 Finding: Eligibility – Determining Federal Direct Student Loan Awards Applicable Regulation: Per 34 CFR 686.203(b)(iii), in the case of a graduate or professional student for a period of enrollment beginning on or after July 1, 2012, the total amount the student may borrow for any academic year of study under the Direct Unsubsidized Loan program may not exceed $8,500. Per 34 CFR 685.203(c)(2)(v), the additional amount that a student described in paragraph (c)(1)(i) of this section may borrow under the Direct Unsubsidized Loan Program for any academic year of study may not exceed the following: in the case of a graduate or professional student, $12,000. Finding: During testing of eligibility, 7 out of 7 students selected for testing were over awarded Unsubsidized Federal Direct Loans. KHSC improperly awarded 61 out of 61 students Unsubsidized Federal Direct Loan in excess of the maximum amount for one academic year, amounting to [$4,445] per student, for a cumulative over award of [$271,146]. Summary: Prior to the commencement of the independent audit conducted for the fiscal year ended May 31, 2023, the institution discovered that it had over awarded Unsubsidized Federal Direct Loan funds to its students. Specifically, the institution awarded additional Unsubsidized Federal Direct Loan funds based on 12-month academic calendar instead of prorating the award based on a 10-month academic calendar. This error resulted in an over award of [$4,445] per student. The institution conducted a file review and refunded all amounts owed to the Federal Student Aid programs because of the file review. The institution also informed the auditor of this error. Corrective Action Taken or Planned: Once the above noted error was discovered, the institution conducted an audit of all student aid packages for students enrolled in the 2022-2023 academic year. It was determined that 61 current students had been over awarded by a net amount of $4,445, for a total of $271,146. Findings were compiled and a plan was created to return over awarded funds and communicate the error to students. The institution also consulted with the Department of Education to confirm its revised calculation was appropriate. The institution returned the funds between July 5-July 20, 2023. Further, the institution made students whole by forgiving any student balances that would have been paid by the over award amount. Emails were sent to all impacted students on July 3, 2023 notifying them of the error. The institution also subsequently notified students that any account balance that remained based on the reversal of the over award would be forgiven. Students who received an estimate financial aid award with the incorrect figures, but who had not yet received aid, were notified of the error and provided updated award information. To ensure this does not happen again the institution has updated their internal student finance audit to include a review of all aid eligibility in conjunction with the next year’s academic calendar for each class of students. Upon any determination that future aid should be prorated, calculation(s) will be completed and reviewed with leadership before implementation. An internal review and approval process will then be enacted and documented. The institution informed RSM of this error and the corrective actions taken. Contact Person Lawrence McGhee, Associate Vice President of Financial Aid, lawrencemcghee@tcsedsystem.edu Completion Date July 20, 2023

Categories

Questioned Costs Student Financial Aid Eligibility Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 947629 2023-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $5.06M