Finding 399030 (2023-007)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-05-30
Audit: 307647
Organization: Wheeling Jesuit University INC (WV)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The University failed to provide documentation for monthly reconciliations of SAS data files, indicating a lack of compliance with federal requirements.
  • Impacted Requirements: Monthly reconciliation of School Account Statement data files to financial records is mandatory, and this oversight is a repeat finding from the previous year.
  • Recommended Follow-Up: Enhance internal controls and procedures to ensure timely and documented reconciliations, utilizing improved backup systems to prevent future data loss.

Finding Text

Finding 2023-007 – N. Special Tests and Provisions – Borrower Data and Reconciliation Information on Federal Program(s) - Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement - Each month, the COD provides institutions with a School Account Statement (“SAS”) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution’s financial records. Since up to three Direct Loan program years may be open at any given time, institutions may receive three SAS data files each month. Condition – The University was not able to provide supporting documentation to evidence that certain monthly SAS data file reconciliations were performed. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect - The University was not in compliance with the Borrower Data and Reconciliation requirements. Questioned Costs – None. Context – For 1 of 2 SAS reconciliations tested, the University was unable to provide documentation showing that the reconciliation was completed. Indication of Repeat Finding - This is a repeat of prior year Finding 2022-002. Recommendation – We recommend the University enhance its procedures and internal controls to ensure that SAS data files are reconciled monthly. Views of Responsible Officials – For one of two reconciliations tested we were unable to provide documentation that the reconciliation was done. The reconciliation was done, however, there was a server error in the system that caused Wheeling to lose some files. Two of the reconciliation files are missing due to this. We have a Financial Aid Office policy that has been established to ensure that reconciliations are made once a month. Since the loss of the backup system, the files are both saved and printed to avoid any more loss of files. During this period, we were using a now-defunct backup system. We have now moved to multiple backup systems and a new storage server. Our storage server is now a virtual machine with a high availability setup where we have 2 large drive systems continually being mirrored. The backup system has 2 servers with large drive systems. We continually alternate file backups each day as needed. As the backups finish, they are moved up to the cloud each time. Also, we have in place a 30-day non-overwrite policy on the files backed up to the cloud.

Corrective Action Plan

Name of Responsible Individual: Dylan Nowakowski Assistant Director of Financial Aid Corrective Action: For one of two reconciliations tested we were unable to provide documentation that the reconciliation was done. The reconciliation was done, however, there was a server error in the system that caused Wheeling to lose some files. Two of the reconciliation files are missing due to this. We have a Financial Aid Office policy that has been established to ensure that reconciliations are made once a month. Since the loss of the backup system, the files are both saved and printed to avoid any more loss of files. During this period, we were using a now-defunct backup system. We have now moved to multiple backup systems and a new storage server. Our storage server is now a virtual machine with a high availability setup where we have 2 large drive systems continually being mirrored. The backup system has 2 servers with large drive systems. We continually alternate file backups each day as needed. As the backups finish, they are moved up to the cloud each time. Also, we have in place a 30-day non-overwrite policy on the files backed up to the cloud. Anticipated Completion Date: July 2022

Categories

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

Other Findings in this Audit

  • 399013 2023-013
    Material Weakness
  • 399014 2023-014
    Material Weakness
  • 399015 2023-015
    Significant Deficiency
  • 399016 2023-009
    Significant Deficiency Repeat
  • 399017 2023-010
    Significant Deficiency
  • 399018 2023-016
    Significant Deficiency Repeat
  • 399019 2023-009
    Significant Deficiency Repeat
  • 399020 2023-010
    Significant Deficiency
  • 399021 2023-008
    Material Weakness
  • 399022 2023-010
    Significant Deficiency
  • 399023 2023-004
    -
  • 399024 2023-005
    Material Weakness Repeat
  • 399025 2023-009
    Significant Deficiency Repeat
  • 399026 2023-010
    Significant Deficiency
  • 399027 2023-016
    Significant Deficiency Repeat
  • 399028 2023-005
    Material Weakness Repeat
  • 399029 2023-006
    Material Weakness
  • 399031 2023-009
    Significant Deficiency Repeat
  • 399032 2023-010
    Significant Deficiency
  • 399033 2023-016
    Significant Deficiency Repeat
  • 399034 2023-009
    Significant Deficiency Repeat
  • 399035 2023-010
    Significant Deficiency
  • 399036 2023-016
    Significant Deficiency Repeat
  • 399037 2023-011
    Significant Deficiency Repeat
  • 399038 2023-012
    Significant Deficiency Repeat
  • 399039 2023-013
    Material Weakness
  • 399040 2023-014
    Material Weakness
  • 975455 2023-013
    Material Weakness
  • 975456 2023-014
    Material Weakness
  • 975457 2023-015
    Significant Deficiency
  • 975458 2023-009
    Significant Deficiency Repeat
  • 975459 2023-010
    Significant Deficiency
  • 975460 2023-016
    Significant Deficiency Repeat
  • 975461 2023-009
    Significant Deficiency Repeat
  • 975462 2023-010
    Significant Deficiency
  • 975463 2023-008
    Material Weakness
  • 975464 2023-010
    Significant Deficiency
  • 975465 2023-004
    -
  • 975466 2023-005
    Material Weakness Repeat
  • 975467 2023-009
    Significant Deficiency Repeat
  • 975468 2023-010
    Significant Deficiency
  • 975469 2023-016
    Significant Deficiency Repeat
  • 975470 2023-005
    Material Weakness Repeat
  • 975471 2023-006
    Material Weakness
  • 975472 2023-007
    Significant Deficiency Repeat
  • 975473 2023-009
    Significant Deficiency Repeat
  • 975474 2023-010
    Significant Deficiency
  • 975475 2023-016
    Significant Deficiency Repeat
  • 975476 2023-009
    Significant Deficiency Repeat
  • 975477 2023-010
    Significant Deficiency
  • 975478 2023-016
    Significant Deficiency Repeat
  • 975479 2023-011
    Significant Deficiency Repeat
  • 975480 2023-012
    Significant Deficiency Repeat
  • 975481 2023-013
    Material Weakness
  • 975482 2023-014
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $6.40M
43.009 Cross Agency Support $2.30M
84.063 Federal Pell Grant Program $867,442
84.425 Education Stabilization Fund $486,600
93.859 Biomedical Research and Research Training $242,923
84.007 Federal Supplemental Educational Opportunity Grants $195,567
84.033 Federal Work-Study Program $75,998
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $9,430
84.038 Federal Perkins Loan Program $0