FAC Explorer

Finding 389364 (2023-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-29
Audit: 300369
Organization: South Carolina State University (SC)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The University disbursed Title IV aid to 14 transfer students without waiting the required 7 days after notifying NSLDS, violating compliance rules.
  • Impacted Requirements: This finding relates to the Special Tests and Provisions for disbursements to transfer students, indicating a lack of adherence to federal monitoring protocols.
  • Recommended Follow-Up: The University should strengthen internal controls and procedures for transfer monitoring, including hiring key staff and engaging an external consultant for process improvement.

Finding Text

Identification of the Federal Program: Student Financial Assistance Cluster (“SFA Cluster”) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students – Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (“NSLDS”) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student’s financial aid history by accessing the NSLDS Financial Aid Professional website. Condition: For 14 students selected for transfer monitoring testing, the University did not wait 7 days after it informed NSLDS about a transfer student before disbursing Title IV aid to those students. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions – Disbursements to or on Behalf of Students for transfer students. Questioned Costs: None. Context: Exceptions were noted for 14 of 24 students selected for transfer monitoring testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2022-003. Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance. Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies. In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department. Management and implementation of current corrective plans are critical to the compliance efforts of the University: The University has made the necessary changes to the staff and will continue to assess the efficiency of the review process to include, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University’s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. As this is a repeated finding, the University ‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance offices (Director of Financial Aid and Director of Transfer Students). The University is requesting a report be filed on the status of our transfer students on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle. In short, the University will enhance its oversight and management of the corrective action plans through the new internal audit unit until this matter has been resolved.

Categories

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions Matching / Level of Effort / Earmarking Subrecipient Monitoring Reporting

Other Findings in this Audit

  • 389363 2023-001
    Significant Deficiency Repeat
  • 389365 2023-001
    Significant Deficiency Repeat
  • 389366 2023-001
    Significant Deficiency Repeat
  • 389367 2023-002
    Significant Deficiency Repeat
  • 389368 2023-002
    Significant Deficiency Repeat
  • 389369 2023-002
    Significant Deficiency Repeat
  • 389370 2023-002
    Significant Deficiency Repeat
  • 389371 2023-003
    Significant Deficiency Repeat
  • 389372 2023-003
    Significant Deficiency Repeat
  • 389373 2023-004
    Significant Deficiency
  • 389374 2023-004
    Significant Deficiency
  • 389375 2023-004
    Significant Deficiency
  • 389376 2023-004
    Significant Deficiency
  • 389377 2023-005
    Significant Deficiency Repeat
  • 389378 2023-006
    Significant Deficiency
  • 389379 2023-006
    Significant Deficiency
  • 389380 2023-006
    Significant Deficiency
  • 389381 2023-006
    Significant Deficiency
  • 965805 2023-001
    Significant Deficiency Repeat
  • 965806 2023-001
    Significant Deficiency Repeat
  • 965807 2023-001
    Significant Deficiency Repeat
  • 965808 2023-001
    Significant Deficiency Repeat
  • 965809 2023-002
    Significant Deficiency Repeat
  • 965810 2023-002
    Significant Deficiency Repeat
  • 965811 2023-002
    Significant Deficiency Repeat
  • 965812 2023-002
    Significant Deficiency Repeat
  • 965813 2023-003
    Significant Deficiency Repeat
  • 965814 2023-003
    Significant Deficiency Repeat
  • 965815 2023-004
    Significant Deficiency
  • 965816 2023-004
    Significant Deficiency
  • 965817 2023-004
    Significant Deficiency
  • 965818 2023-004
    Significant Deficiency
  • 965819 2023-005
    Significant Deficiency Repeat
  • 965820 2023-006
    Significant Deficiency
  • 965821 2023-006
    Significant Deficiency
  • 965822 2023-006
    Significant Deficiency
  • 965823 2023-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $21.02M
84.063 Federal Pell Grant Program $9.26M
84.031 Higher Education_institutional Aid $4.51M
10.205 Payments to 1890 Land-Grant Colleges and Tuskegee University $2.27M
10.512 Agriculture Extension at 1890 Land-Grant Institutions $1.88M
84.007 Federal Supplemental Educational Opportunity Grants $1.26M
93.397 Cancer Centers Support Grants $707,114
10.524 Scholarships for Students at 1890 Institutions (b) $558,121
84.263 Innovative Rehabilitation Training $468,570
93.516 Affordable Care Act (aca) Public Health Training Centers Program $463,725
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $387,807
84.425 Covid-19 - Heerf Supplemental Support Under the American Rescue Plan $371,663
10.216 1890 Institution Capacity Building Grants $339,780
84.425 Covid-19 - Heerf Historically Black Colleges and Universities (hbcus) $330,881
84.382 Strengthening Minority-Serving Institutions $319,334
84.042 Trio_student Support Services $298,382
81.RD Department of Energy $295,155
84.033 Federal Work-Study Program $275,957
59.037 Small Business Development Centers $266,761
59.059 Congressional Grant $208,539
10.311 Beginning Farmer and Rancher Development Program $193,447
84.120 Minority Science and Engineering Improvement $193,352
84.129 Rehabilitation Long-Term Training $182,600
47.076 Education and Human Resources $179,962
10.514 Expanded Food and Nutrition Education Program $158,309
20.701 University Transportation Centers Program $151,862
10.912 Environmental Quality Incentives Program $132,033
10.902 Soil and Water Conservation $128,326
84.264 Rehabilitation Training_continuing Education $111,363
81.104 Environmental Remediation and Waste Processing and Disposal $101,917
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $92,022
12.910 U.s. Department of Defense $85,638
81.137 Minority Economic Impact $83,778
10.500 Cooperative Extension Service $73,872
84.116 Fund for the Improvement of Postsecondary Education $70,108
47.083 Integrative Activities $69,847
10.523 Centers of Excellence at 1890 Institutions (b) $69,816
10.443 Outreach and Assistance for Socially Disadvantaged and Veteran Farmers and Ranchers $55,433
10.525 Farm and Ranch Stress Assistance Network Competitive Grants Program (b) $43,108
12.598 Centers for Academic Excellence $36,835
10.025 Plant and Animal Disease, Pest Control, and Animal Care $35,910
10.515 Renewable Resources Extension Act and National Focus Fund Projects $34,003
93.350 National Center for Advancing Translational Sciences $24,403
10.771 Rural Cooperative Development Grants $16,549
11.431 Climate and Atmospheric Research $12,127
10.960 Technical Agricultural Assistance $11,600
84.027 Special Education_grants to States $6,788
10.170 Specialty Crop Block Grant Program - Farm Bill $6,708
81.049 Office of Science Financial Assistance Program $6,679
43.008 Education $6,000
93.866 Aging Research $5,583
11.417 Sea Grant Support $4,669
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $3,772
47.049 Mathematical and Physical Sciences $3,629
20.237 Commercial Vehicle Information Systems and Networks $2,550
10.328 National Food Safety Training, Education, Extension, Outreach, and Technical Assistance Competitive Grants Program $2,192
16.607 Bulletproof Vest Partnership Program $1,832
45.129 Promotion of the Humanities_federal/state Partnership $554
84.038 Federal Perkins Loan Program $0