Finding 387847 (2023-003)

Significant Deficiency
Requirement
G
Questioned Costs
-
Year
2023
Accepted
2024-03-28
Audit: 299883
Auditor: Rsm US LLP

AI Summary

  • Core Issue: The Conservatory lacked a process to track the institutional share of federal work-study compensation, risking excess federal fund drawdowns.
  • Impacted Requirements: Compliance with 34 CFR 675.26(a)(1) regarding federal work-study compensation limits was not maintained due to missing reconciliations.
  • Recommended Follow-Up: Implement a formal tracking and reconciliation process for federal work-study payments, ensuring proper recording and retention of review evidence.

Finding Text

U.S. Department of Education Student Financial Assistance Cluster Federal Work-Study Program Year ended June 30, 2023 ALN 84.033 Criteria: Per 34 CFR 675.26 (a)(1), the federal share of federal work study compensation paid to a student employed other than by a private for-profit organization, as described in CFR 675.23, may not exceed 75% unless otherwise approved. Condition: The Conservatory did not have a process in place to track and record into the accounting records the institutional share of the federal work study as amounts were paid to students during the year. Cause: Due to turnover within the accounting and student financial aid departments, the reconciliation process was not performed during the year. Effect: A lack of reconciliation of the institutional matching requirement could result in excess federal funds being drawn down during the year. Questioned costs: None identified. Prevalence: There was no reconciliation process during the year to record the institutional match for federal work study funds paid to students during the year. Total earned compensation for the federal work study program was $300,100. Repeat finding: This is not a repeat finding. Recommendation: We recommend the Conservatory implement a formal process throughout the year to ensure federal work study amounts paid to students are recorded between the institutional and federal share. In addition, a reconciliation process should be implemented to ensure amounts are properly recorded and this reconciliation should be reviewed and evidence of the review should be retained. View of responsible officials and planned corrective actions: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Finding No. 2023 – 003 - Tracking Institutional Share of Federal Work Study Finding: The Conservatory did not have a process in place to track and record into the accounting records the institutional share of the federal work study as amounts were paid to students during the year. Corrective Action Taken or Planned: During fiscal year 2023 both the Business Office and Office of Financial Aid experienced significant turnover. This finding been corrected by staff possessing experience with the regulations related to federal work study. The Conservatory did meet the overall institutional share requirement, but this was not adequately documented. Documentation and reconciliation processes have been put in place to ensure compliance moving forward. Completed October, 2023. Responsible Person: Richard Bowman, Controller

Categories

Student Financial Aid Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 387848 2023-004
    Significant Deficiency
  • 964289 2023-003
    Significant Deficiency
  • 964290 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $5.76M
84.038 Federal Perkins Loans $1.21M
84.033 Federal Work-Study Program $248,898
84.063 Federal Pell Grant Program $170,399
84.007 Federal Supplemental Educational Opportunity Grants $132,274
97.036 Covid-19 Disaster Grants - Public Assistance (presidentially Declared Disasters) $65,000