Finding 390245 (2023-003)

Significant Deficiency Repeat Finding
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-03-29
Audit: 301132
Organization: National University (CA)
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance related to the calculation of students' cost of attendance, affecting federal student aid eligibility.
  • Impacted Requirements: The calculations for cost of attendance did not align with the established policy, leading to potential inaccuracies in financial need assessments.
  • Recommended Follow-Up: Implement a review process for cost of attendance budgets, ensure timely documentation, and provide training to staff to prevent future discrepancies.

Finding Text

FINDING 2023-003 - Eligibility - Significant Deficiency in Internal Control over Compliance (See III. Federal Awards Findings and Questioned Costs - Finding 2023-003 for table) Criteria- SEC. 472 of the Higher Education Act (HEA) [20 U.S.C. 108711] COST OF ATTENDANCE. For the purpose of this title, the term "cost of attendance" means: (1) tuition and fees normally assessed a student carrying the same academic workload as determined by the institution and including costs for rental or purchase of any equipment, materials, or supplies required of all students in the same course of study. Condition/context- We selected 40 students from a list of all students enrolled and awarded federal student aid in fiscal year 2023. We obtained the students' cost of attendance calculations and compared them to their established cost of attendance policy, published tuition rates, and other supporting documents. Four of the selected students had cost of attendance that included the incorrect budget for fees. Cause - The exceptions occurred as a result of the lack of effective internal controls in place to review completed financial aid packages against approved University budgets. Effect- The students' financial need is calculated based on the students' expected family contribution and estimated cost of attendance, which in turn is used to determine eligibility for programs and packages the student's award offers. If the cost of attendance is incorrect, this could result in an over- or under­award. In our testing, we did not identify students who were over-awarded or under-awarded resulting from this specific condition. Repeat finding - This is a repeat finding. See 2022-003 Recommendation - We recommend NU institute a process and control to ensure student cost of attendance budgets are reviewed by the appropriate person(s) in a timely manner and that the review is documented. Views of responsible officials and planned corrective actions - Management acknowledges the audit finding and wants to reinforce that despite challenges in the cost of attendance; there were no over or under-awards to students. To address this finding, our Quality Assurance team will oversee a weekly review of the cost of attendance to ensure financial aid packages align with approved budgets, enabling early identification of discrepancies for prompt correction. Based on these reviews, individual and group coaching will be implemented to address areas of concern. A refresher training and updated tools and guidance will be completed to reinforce best practices and align with institutional policy and procedure for calculating the cost of attendance. Through these concerted efforts, NU hopes to demonstrate its full commitment to addressing the audit findings.

Categories

Procurement, Suspension & Debarment Eligibility Significant Deficiency Equipment & Real Property Management Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 390234 2023-001
    Material Weakness Repeat
  • 390235 2023-002
    Material Weakness Repeat
  • 390236 2023-003
    Significant Deficiency Repeat
  • 390237 2023-001
    Material Weakness Repeat
  • 390238 2023-002
    Material Weakness Repeat
  • 390239 2023-003
    Significant Deficiency Repeat
  • 390240 2023-001
    Material Weakness Repeat
  • 390241 2023-002
    Material Weakness Repeat
  • 390242 2023-003
    Significant Deficiency Repeat
  • 390243 2023-001
    Material Weakness Repeat
  • 390244 2023-002
    Material Weakness Repeat
  • 390246 2023-001
    Material Weakness Repeat
  • 390247 2023-002
    Material Weakness Repeat
  • 390248 2023-003
    Significant Deficiency Repeat
  • 390249 2023-001
    Material Weakness Repeat
  • 390250 2023-002
    Material Weakness Repeat
  • 390251 2023-003
    Significant Deficiency Repeat
  • 966676 2023-001
    Material Weakness Repeat
  • 966677 2023-002
    Material Weakness Repeat
  • 966678 2023-003
    Significant Deficiency Repeat
  • 966679 2023-001
    Material Weakness Repeat
  • 966680 2023-002
    Material Weakness Repeat
  • 966681 2023-003
    Significant Deficiency Repeat
  • 966682 2023-001
    Material Weakness Repeat
  • 966683 2023-002
    Material Weakness Repeat
  • 966684 2023-003
    Significant Deficiency Repeat
  • 966685 2023-001
    Material Weakness Repeat
  • 966686 2023-002
    Material Weakness Repeat
  • 966687 2023-003
    Significant Deficiency Repeat
  • 966688 2023-001
    Material Weakness Repeat
  • 966689 2023-002
    Material Weakness Repeat
  • 966690 2023-003
    Significant Deficiency Repeat
  • 966691 2023-001
    Material Weakness Repeat
  • 966692 2023-002
    Material Weakness Repeat
  • 966693 2023-003
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $227.33M
84.063 Federal Pell Grant Program $14.52M
84.425 Covid-19 - Education Stabilization Fund - Higher Education Emergency Relief Fund (heerf) - Student Portion $5.02M
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $2.42M
84.038 Feeral Perkins Loan Program $2.39M
84.425 Covid-19 - Education Stabilization Fund - Higher Education Emergency Relief Fund (heerf) - Supplemental Support Under the American Rescue Plan Allocation Table $1.39M
84.425 Covid-19 - Education Stabilization Fund - Higher Education Emergency Relief Fund (heerf) - Institutional Portion $737,557
84.007 Federal Supplemental Educational Opportunity Grants $460,898
93.359 Nurse Education, Practice Quality and Retention Grants $210,575
84.411 Education Innovation Research $110,700
84.031 Access $108,744
47.070 Computer and Information Science and Engineering $103,437
47.074 Biological Sciences $42,093
84.336 Teacher Quality Partnership Grants $41,653
12.903 Gencyber Teacher Program $41,159
93.124 Nurse Anesthetist Traineeships $27,250
84.033 Federal Work-Study Program $16,724