FAC Explorer

Finding 372378 (2023-001)

Significant Deficiency Repeat Finding
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-03-05
Audit: 293636
Organization: Point University, Inc. and Subsidiaries (GA)
Auditor: Cliftonlarsonallen LLP

AI Summary

  • Core Issue: There are discrepancies in disbursement dates for Direct Loans and Pell grants, leading to potential noncompliance with federal regulations.
  • Impacted Requirements: The institution failed to meet the requirements outlined in 34 CFR 685.301(a)(2)(iii) and 34 CFR 690.83(b)(2) regarding accurate reporting of disbursement dates.
  • Recommended Follow-Up: The University should review and update its policies and procedures to ensure accurate reporting to the Common Origination and Disbursement (COD) system.

Finding Text

Federal program title: Student Financial Aid Cluster Assistance Listing Number: 84.033, 84.063, 84.007, 84.379, 84.268 Federal Award Identification Number and Year: P033A223771 (CWS 22‐23), P063P220377 (Pell 22‐23), P007A223771 (SEOG 22‐23), P268K230377 (Direct Loan 2023) Award Period: July 1, 2022, through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.301(a)(2)(iii) outlines that an institution must provide the anticipated and actual disbursements dates of loan proceeds. In addition, The Code of Federal Regulations, 34 CFR 690.83(b)(2) outlines that an institution must provide the other information (Disbursement information for Pell) in an appropriate manor. Condition: Disbursement dates recorded on student accounts for Direct Loan and Pell disbursements did not agree to the disbursement date reported to Common Origination and Disbursement (COD). Questioned costs: Unknown as incorrect dates ultimately affect interest on Direct Loans. Context: In 3 of the 60 students tested, we noted discrepancies in disbursement dates when comparing disbursements dates in Campus Nexus to what was ultimately reported to COD. Cause: Lack of appropriate policy and procedure in place regarding reporting of students to COD for the year under audit. Effect: Noncompliance with federal regulations which could lead to incorrect repayment terms for students. Repeat Finding: Yes – 2022-002 Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting to COD. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.

Corrective Action Plan

Disbursement Dates (repeat) Finding: As noted in the audit report, there were three instances in 60 files in which there were discrepancies in disbursement dates. Disbursement dates recorded on student accounts for Direct Loan and Pell disbursements did not agree to the disbursement date reported to Common Origination and Disbursement (COD). Auditors' Recommendation: The University should review their policies and procedures to ensure accurate reporting to COD. School Response: The University agrees with this finding and has initiated corrective action. Corrective Action Plan: Title IV disbursements must be posted to student accounts within 15 days of the funds drawdown. Also, the disbursement date per COD must match the disbursement date on the student account. There was one instance in which the Disbursement date for a Pell Grant was 10/10/2022 per COD and 10/19/2022 on the student's account. One instance had a disbursement date at COD as 2/16/2023 and at 2/15/2023 on the student's account. The third instance had a disbursement date of 1/25/23 at COD and 1/26/23 on the student's account. Each of these disbursements were posted in the old Student Information System (SIS), Anthology. The posting process that the school used under the previous system relied primarily on manual checks by employees in various departments in which reports could be sent to COD in which the posting dates did not match the COD dates. In order to avoid this finding in the future, the University has sought out and implemented a new Student Information System (SIS), Colleague, beginning with the 2023-24 award year. The school has also contracted with a third-party servicer, Financial Aid Services (FAS}, to assist with packaging students and completing the disbursement process. To disburse funds, the Director of Financial Aid Quality and Compliance or the representative from FAS runs a report in Colleague which pulls scheduled and approved financial aid disbursements for students who have met the enrollment criteria to receive those disbursements. The report goes to the student accounts office where the financial aid is posted to the student ledgers. Then it is transmitted to COD with the posted dates so that the dates reported to COD match the dates in the SIS. If there are any errors in the transmission, the Director of Financial Aid Quality and Compliance or the representative from FAS will review the rejected disbursements and make corrections to get them processed as quickly as possible. The accounting office submits the drawdown request to G-5 for the amount of the approved and posted financial aid. The new process in which the disbursement amounts and dates transmitted to COD match the disbursement amounts and dates posted to the students' ledgers is expected to ensure compliance in the future. Name(s) of the contact person(s) responsible for corrective action: Director of Financial Aid Quality and Compliance, Rachal Wortham Planned completion date for corrective action plan: • New Colleague SIS implemented live beginning in the Fall semester 2023. • Training on new disbursement process completed August 2023. • First disbursements approved using the new SIS done by Director of Financial Aid Quality and Compliance August 2023. • Review of disbursement process with FAS October 2023. • Follow up with Colleague team to review the process and work out any flaws February 2024.

Categories

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

Other Findings in this Audit

  • 372379 2023-002
    Significant Deficiency Repeat
  • 372380 2023-003
    Significant Deficiency
  • 372381 2023-004
    Significant Deficiency
  • 372382 2023-001
    Significant Deficiency Repeat
  • 372383 2023-002
    Significant Deficiency Repeat
  • 372384 2023-003
    Significant Deficiency
  • 372385 2023-004
    Significant Deficiency
  • 372386 2023-001
    Significant Deficiency Repeat
  • 372387 2023-002
    Significant Deficiency Repeat
  • 372388 2023-003
    Significant Deficiency
  • 372389 2023-004
    Significant Deficiency
  • 372390 2023-001
    Significant Deficiency Repeat
  • 372391 2023-002
    Significant Deficiency Repeat
  • 372392 2023-003
    Significant Deficiency
  • 372393 2023-004
    Significant Deficiency
  • 948820 2023-001
    Significant Deficiency Repeat
  • 948821 2023-002
    Significant Deficiency Repeat
  • 948822 2023-003
    Significant Deficiency
  • 948823 2023-004
    Significant Deficiency
  • 948824 2023-001
    Significant Deficiency Repeat
  • 948825 2023-002
    Significant Deficiency Repeat
  • 948826 2023-003
    Significant Deficiency
  • 948827 2023-004
    Significant Deficiency
  • 948828 2023-001
    Significant Deficiency Repeat
  • 948829 2023-002
    Significant Deficiency Repeat
  • 948830 2023-003
    Significant Deficiency
  • 948831 2023-004
    Significant Deficiency
  • 948832 2023-001
    Significant Deficiency Repeat
  • 948833 2023-002
    Significant Deficiency Repeat
  • 948834 2023-003
    Significant Deficiency
  • 948835 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $4.21M
84.063 Federal Pell Grant Program $3.09M
84.007 Federal Supplemental Educational Opportunity Grants $66,406
84.033 Federal Work-Study Program $54,868