Finding 391643 (2023-002)

Material Weakness
Requirement
E
Questioned Costs
$1
Year
2023
Accepted
2024-04-01
Audit: 302079
Organization: Dillard University (LA)

AI Summary

  • Core Issue: Two students received loans exceeding the aggregate loan limit by $3,803, and three students exceeded the annual loan limit by $2,966.
  • Impacted Requirements: The University did not comply with Title IV regulations regarding loan disbursement eligibility.
  • Recommended Follow-Up: Implement additional training and system flags to ensure compliance and monitor loan limits effectively.

Finding Text

Audit Finding Reference Number Questioned Cost 2023-002 – Annual and Aggregate Loan Limits $6,769 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.268 Federal Direct Student Loan (Direct) Federal Award Year June 30, 2023 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria Title IV regulations, 34 CFR 685.203 (a) stipulates annual loan limits based upon the undergraduate student’s completed years of program of undergraduate education. The annual loan limit for a student who has not completed the 1st year of study is $3,500, 2nd year of study is $4,500 and remainder of the program is $5,500. Title IV regulations, 34 CFR 685.203 (b) stipulates that a dependent student may receive an additional unsubsidized loan in the amount of $2,000. Students whose parents are likely to be precluded by exceptional circumstances from receiving a PLUS loan may be eligible for an unsubsidized loan beyond the base amount of $2,000. CFR 685.203(d) stipulates the aggregate unpaid principal amount of all Direct subsidized loans made to a student but excluding the amount of capitalized interest may not exceed (1) $23,000 in the case of any student who has not successfully completed a program of study at the undergraduate level and (2) $65,500 in the case of a graduate or professional student, including loans for undergraduate study. The total amount of Direct unsubsidized loans but excluding the amount of capitalized interest may not exceed (1) for a dependent undergraduate student, $23000, or, effective July 1, 2008, $31,000, minus any Direct subsidized loan, and (2) for an independent undergraduate or a dependent undergraduate who qualifies for additional eligibility, $57,500, minus any Direct subsidized loan. Conditions and Context I noted during my audit: • two (2) students out of twenty-five (25) tested received direct loans in excess of the aggregate loan limit totaling $3,803, and • three (3) students out of twenty-one (21) tested who received subsidized loans in excess of the annual loan limit totaling $2,966. However, the University has made adjustments to the student’s billing statements and returned the funds to the Department of Education prior to issuance of the report. Cause It appears that the University did not ensure that the student was eligible to receive the loan proceeds. Questioned Costs For the purposes of this condition, I have questioned costs totaling $6,769 related to the Direct loan program. Effect The University has not adhered to Title IV regulations regarding the disbursing of loan funds in accordance with the regulations. However, the University has made adjustments to the student’s billing statements and returned the funds to the Department of Education prior to issuance of the report. Repeat Finding No.   Management’s Response The system is being reviewed to ensure flags are set not only from the Central Process System (CPS) on the ISIR as an alert, but to implement secondary measures in PowerFaids to flag the student’s electronic file record as part of the communication process that the counseling unit must review. Staff will be counseled, and additional training is being provided to ensure all staff are knowledgeable and conscientious of policy, review and the calculation process when determining yearly and aggregate loan limits. The University will be implementing Transfer Monitoring, which has been discussed as preparation for bringing up a new system.

Corrective Action Plan

The system is being reviewed to ensure flags are set not only from the Central Process System (CPS) on the ISIR as an alert, but to implement secondary measures in PowerFaids to flag the student’s electronic file record as part of the communication process that the counseling unit must review. Staff will be counseled and additional training is being provided to ensure all staff are knowledgeable and conscientious of policy, review and the calculation process when determining yearly and aggregate loan limits. The University will be implementing Transfer Monitoring which has been discussed as preparation of bringing up a new system.

Categories

Questioned Costs Student Financial Aid Subrecipient Monitoring Matching / Level of Effort / Earmarking Eligibility

Other Findings in this Audit

  • 391640 2023-001
    Material Weakness Repeat
  • 391641 2023-001
    Material Weakness Repeat
  • 391642 2023-001
    Material Weakness Repeat
  • 968082 2023-001
    Material Weakness Repeat
  • 968083 2023-001
    Material Weakness Repeat
  • 968084 2023-001
    Material Weakness Repeat
  • 968085 2023-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $10.19M
84.063 Federal Pell Grant Program $4.68M
84.031 Higher Education_institutional Aid $3.66M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $3.21M
84.425 Education Stabilization Fund $863,409
12.630 Basic, Applied, and Advanced Research in Science and Engineering $508,029
84.033 Federal Work-Study Program $391,327
84.044 Trio_talent Search $367,280
84.007 Federal Supplemental Educational Opportunity Grants $325,203
12.800 Air Force Defense Research Sciences Program $212,898
93.859 Biomedical Research and Research Training $147,140
84.217 Trio_mcnair Post-Baccalaureate Achievement $140,002
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $137,552
84.120 Minority Science and Engineering Improvement $136,740
84.042 Trio_student Support Services $114,406
93.368 21st Century Cures Act - Precision Medicine Initiative $106,219
45.162 Promotion of the Humanities_teaching and Learning Resources and Curriculum Development $79,358
93.364 Nursing Student Loans $68,950
43.008 Education $55,633
47.050 Geosciences $46,599
47.075 Social, Behavioral, and Economic Sciences $38,877
81.049 Office of Science Financial Assistance Program $24,004
47.070 Computer and Information Science and Engineering $12,052
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $9,983
47.076 Education and Human Resources $8,571
19.009 Academic Exchange Programs - Undergraduate Programs $7,143
93.307 Minority Health and Health Disparities Research $5,900
43.001 Science $3,511