Finding 387117 (2023-003)

-
Requirement
E
Questioned Costs
$1
Year
2023
Accepted
2024-03-28
Audit: 299424
Organization: Eureka College (IL)
Auditor: Sikich LLP

AI Summary

  • Core Issue: Three out of 40 student files had improper Direct Loan awards, including one student receiving subsidized instead of unsubsidized loans.
  • Impacted Requirements: Noncompliance with 34 CFR 682.201 and 34 CFR 668.164 regarding loan eligibility and disbursement reporting.
  • Recommended Follow-Up: Review and improve policies to ensure accurate Title IV aid awards and correct reporting of disbursement dates to the NSLDS.

Finding Text

2023-003 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Criteria: 34 CFR 682.201 (a) (1-2) notes, “(1) To obtain a Direct Subsidized Loan or a Direct Unsubsidized Loan, a student must complete a Free Application for Federal Student Aid and submit it in accordance with instructions in the application. (2) If the student is eligible for a Direct Subsidized Loan or a Direct Unsubsidized Loan, the school in which the student is enrolled must perform the following functions: (i) create a loan origination record and transmit the record to the Secretary. (ii) Ensure that the loan is supported by a completed Master Promissory Note (MPN) and, if applicable, transmit the MPN to the Secretary. (iii) In accordance with 34 CFR 668.162, draw down funds or receive funds from the Secretary, and disburse the funds to the student.” Criteria: 34 CFR 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with- (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds; Condition: We examined 40 student files and we noted 3 out of 40 students were not properly awarded Direct Loans. One of these students was improperly awarded subsidized loans and instead should have received unsubsidized loans. Additionally, the College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider these conditions to be instances of noncompliance in internal control over compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $5,252 Cause and Effect: For the awards, without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. For the disbursement date, the College posted the batches incorrectly resulting in a variance in the date of the disbursement per the student account and the date per NSLDS. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid and implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

Corrective Action Plan

2023-003 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: We examined 40 student files and we noted 3 out of 40 students were not properly awarded Direct Loans. One of these students was improperly awarded subsidized loans and instead should have received unsubsidized loans. Additionally, the College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider these conditions to be instances of noncompliance in internal control over compliance relating to the Eligibility compliance requirement. Management Response: Cost of Attendance (COA) calculations were not updated to ensure ratio of subsidized versus unsubsidized loans were correct. It looks like awards were not being recalculated as additional need based aid was added to awards for these students. Corrective Action Plan: New financial aid software (JFA) was implemented for the 2023-2024 academic year. A component of this software is a compliance check for COA and other issues. The compliance check for over awards should catch instances of the wrong sub/unsub ratio in the future. Responsible Person: Tim Marten, Director of Financial Aid Implementation Date: Fall 2023

Categories

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

Other Findings in this Audit

  • 387115 2023-001
    Significant Deficiency
  • 387116 2023-002
    Significant Deficiency
  • 387118 2023-004
    -
  • 963557 2023-001
    Significant Deficiency
  • 963558 2023-002
    Significant Deficiency
  • 963559 2023-003
    -
  • 963560 2023-004
    -

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $3.15M
84.063 Federal Pell Grant Program $1.34M
11.307 Economic Adjustment Assistance $160,769
84.038 Federal Perkins Loan Program $94,634
84.033 Federal Work-Study Program $60,000
84.007 Federal Supplemental Educational Opportunity Grants $57,084
45.301 Museums for America $17,820
84.425 Education Stabilization Fund $8,479
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $3,772