Finding 391964 (2023-002)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-04-01
Audit: 302137
Organization: Presbyterian College (SC)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The College disbursed Title IV aid to transfer students without notifying NSLDS first, violating federal requirements.
  • Impacted Requirements: Compliance with the NSLDS Student Transfer Monitoring Process is mandatory to ensure accurate financial aid eligibility.
  • Recommended Follow-Up: Improve administrative oversight and internal controls to meet transfer monitoring requirements and prevent future violations.

Finding Text

Federal Program Information: Federal Direct Student Loans (ALN #84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 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 Students Loan Data System (the “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 during the 7-day period or if it obtains the student's financial aid history by accessing the NSLDS Financial Aid Professional website. When a school receives an alert from NSLDS, before making a disbursement of Title IV aid, it must determine if the change to the student's financial aid history affects the student's eligibility (34 CFR section 668.19). Condition: Instances were identified where the College disbursed Title IV aid prior to informing NSLDS about transfer students. Cause: Lack of administrative oversight and insufficient internal controls with respect to transfer monitoring requirements. Effect or Potential Effect: The College was not in compliance with the transfer monitoring requirements. Questioned Costs: None. Context: For 2 of 2 students selected for testing, the College did not properly inform NSLDS of transfer students prior to disbursing Title IV aid. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-004. Recommendation: We recommend the College enhance its procedures and internal controls to ensure compliance with transfer monitoring requirements. Views of Responsible Officials:

Corrective Action Plan

Individuals Responsible for Corrective Action Plan: Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-002 For 2 of 2 mid-year transfer students tested, the school did not actively add these students to the NSLDS transfer monitoring list. Corrective Action Plan: While the college experienced significant turnover in its staffing in fiscal years 2021 and 2022, the college has historically reviewed the NSLDS history of transfer students to ensure they were not enrolled or receiving a disbursement for the current term at another institution. Any student that showed a pending disbursement on COD would be notified to inform their previous college and request the pending disbursement be removed. Starting in the fall 2023, the transfer monitoring tool was utilized along with reviewing NSLDS history.

Categories

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

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
10.766 Community Facilities Loans and Grants $58.41M
84.268 Federal Direct Student Loans $15.54M
84.063 Federal Pell Grant Program $1.45M
21.027 Coronavirus State and Local Fiscal Recovery Funds $593,347
84.033 Federal Work-Study Program $129,877
93.859 Biomedical Research and Research Training $121,441
84.007 Federal Supplemental Educational Opportunity Grants $107,905
47.050 Geosciences $52,754
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $7,544
43.008 Undergraduate Student Research Award $7,500
43.008 Space Grant Campus Director $1,500
84.038 Federal Perkins Loan Program $0