Finding 390082 (2023-003)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-29
Audit: 300954
Organization: Aims College District (CO)

AI Summary

  • Core Issue: The College failed to disclose required information about its third-party servicer arrangements on its website and did not provide the necessary URL to the Department of Education.
  • Impacted Requirements: This non-compliance violates Title IV regulations regarding disclosures for Tier One and Tier Two arrangements, including financial account data and contract details.
  • Recommended Follow-Up: The College should establish procedures to ensure timely compliance with disclosure requirements for third-party servicers and regularly update the necessary information.

Finding Text

Criteria or specific requirement: An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent, to issue a check payment to the student or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. When a school uses such a servicer, a school must disclose conspicuously on its website the contract(s) establishing a Tier One or Tier Two arrangement, except for any portions that, if disclosed, would compromise personal privacy, proprietary information technology, or the security of information technology or of physical facilities (34 CFR 668.164(e)(2)(vi) and 668.164(f)(4)(iii)). Schools with Tier One arrangements or Tier Two arrangements above the threshold must also disclose on their Web site: (a) the total consideration for the year, monetary and non-monetary, paid or received by the parties under the terms of the contract; (b) for any year in which the school's enrolled students open 30 or more financial accounts under the arrangement, (i) the number of students who had financial accounts under the contract at any time during the most recently completed award year, and (ii) the mean and median of the actual costs incurred by those account holders. This disclosure must be updated within 60 days after the end of each award year. A school must also provide to ED an up-to-date URL for the contract for publication in a centralized database accessible to the public. Unless the school has a Tier Two arrangement under the threshold, the URL must also include the contract data described in the paragraph above (34 CFR 668.164(e)(2)(viii); 668.164(f)(4)(iii)(B); 668.164(f)(4)(v)). Condition: The College did not maintain the required information on their website and had not disclosed the URL to the Department of Education. Context: The College did not comply with regulations when using a servicer to make FSA payments to students. Questioned costs: None. Cause: The College was not aware of the disclosure requirements. Effect: The college was not in compliance with Title IV third-party servicer requirements. Repeat Finding: No. Recommendation: We recommend the College implement procedures to identify requirements about disclosures when using third-party servicers and to implement such requirements on a timely basis. Views of responsible officials: Management agrees with the finding.

Categories

Student Financial Aid

Other Findings in this Audit

  • 390080 2023-003
    Significant Deficiency
  • 390081 2023-003
    Significant Deficiency
  • 390083 2023-003
    Significant Deficiency
  • 390084 2023-004
    Significant Deficiency
  • 390085 2023-004
    Significant Deficiency
  • 390086 2023-004
    Significant Deficiency
  • 966522 2023-003
    Significant Deficiency
  • 966523 2023-003
    Significant Deficiency
  • 966524 2023-003
    Significant Deficiency
  • 966525 2023-003
    Significant Deficiency
  • 966526 2023-004
    Significant Deficiency
  • 966527 2023-004
    Significant Deficiency
  • 966528 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $5.72M
84.268 Federal Direct Student Loans $2.13M
21.027 Cosi Finish What You Started $406,335
84.048 Perkins $365,424
21.027 Careforward (coronavirus State & Local Fiscal Recovery Funds) $295,951
84.042 Trio - Sss $292,223
84.042 Trio Sss (stem) $277,916
84.007 Federal Supplemental Educational Opportunity Grants $128,051
84.033 Federal Work-Study Program $72,518
47.076 Stem + Computing K-12 (stem + C) $67,722
43.008 National Space Grant College and Fellowship Program $6,375