FAC Explorer

Finding 401198 (2023-001)

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Requirement
P
Questioned Costs
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Year
2023
Accepted
2024-06-18
Audit: 309212
Organization: The University of Alabama (AL)
Auditor: Pricewaterhousecoopers LLP

AI Summary

  • Core Issue: The University failed to obtain voluntary consent from students for electronic disbursements as required by the E-Sign Act.
  • Impacted Requirements: Compliance with Federal Student Aid regulations regarding electronic transactions is compromised, risking the legal validity of these transactions.
  • Recommended Follow-up: Management should review E-Sign Act requirements and implement processes to ensure consent is captured for future electronic transactions.

Finding Text

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Loan Program $93.75M
84.116 Fund for the Improvement of Postsecondary Education $9.91M
84.038 Student Financial Assistance $4.56M
12.019 Pacific Center Disaster (pdc) Program $3.47M
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $2.44M
93.658 Foster Care Title IV-E $2.11M
84.007 Federal Supplemental Educational Opportunity Grants $1.86M
97.047 Pre-Disaster Mitigation $1.46M
84.423 Supporting Effective Educator Development Program $1.08M
17.504 Consultation Agreements $992,359
93.575 Child Care and Development Block Grant $938,384
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $934,075
59.037 Small Business Development Centers $920,241
93.136 Injury Prevention and Control Research and State and Community Based Programs $765,281
96.009 Social Security State Grants for Work Incentives Assistance to Disabled Beneficiaries $714,950
93.959 Covid-19 Block Grants for Prevention and Treatment of Substance Abuse $651,147
93.639 Section 9813: State Planning Grants for Qualifying Community-Based Mobile Crisis Intervention Services $612,897
84.411 Education Innovation and Research (formerly Investing in Innovation (i3) Fund) $543,035
93.307 Minority Health and Health Disparities Research $530,509
93.264 Nursing Faculty Loan Program (nflp) $529,959
93.732 Mental and Behavioral Health Education and Training Grants $508,986
47.084 Nsf Technology, Innovation, and Partnerships $464,392
93.138 Protection and Advocacy for Individuals with Mental Illness $458,315
20.509 Formula Grants for Rural Areas and Tribal Transit Program $446,014
12.431 Basic Scientific Research $427,023
84.407 Transition Programs for Students with Intellectual Disabilities Into Higher Education $413,731
93.778 Medical Assistance Program $406,158
98.001 Usaid Foreign Assistance for Programs Overseas $376,583
93.867 Vision Research $360,451
84.200 Graduate Assistance in Areas of National Need $333,766
93.173 Research Related to Deafness and Communication Disorders $313,535
84.042 Trio Student Support Services $312,513
81.117 Energy Efficiency and Renewable Energy Information Dissemination, Outreach, Training and Technical Analysis/assistance $302,902
10.580 Supplemental Nutrition Assistance Program, Process and Technology Improvement Grants $298,970
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $288,937
93.310 Trans-Nih Research Support $284,389
12.630 Basic, Applied, and Advanced Research in Science and Engineering $283,587
93.011 National Organizations of State and Local Officials $278,073
66.605 Performance Partnership Grants $258,454
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $255,675
16.575 Crime Victim Assistance $248,216
93.137 Community Programs to Improve Minority Health Grant Program $246,560
10.250 Agricultural and Rural Economic Research, Cooperative Agreements and Collaborations $246,546
93.884 Primary Care Training and Enhancement $233,967
84.240 Program of Protection and Advocacy of Individual Rights $211,187
47.078 Polar Programs $206,442
11.432 National Oceanic and Atmospheric Administration (noaa) Cooperative Institutes $188,216
93.387 National and State Tobacco Control Program $182,878
20.616 National Priority Safety Programs $178,566
84.129 Rehabilitation Long-Term Training $175,990
16.543 Missing Children's Assistance $173,812
11.609 Measurement and Engineering Research and Standards $173,648
81.U01 Contracts - Department of Energy $172,984
11.307 Economic Adjustment Assistance $168,786
45.313 Laura Bush 21st Century Librarian Program $168,510
84.184 School Safely National Activities $155,007
14.913 Healthy Homes Production Program $150,239
19.009 Academic Exchange Programs - Undergraduate Programs $150,083
11.611 Manufacturing Extension Partnership $142,242
45.149 Promotion of the Humanities Division of Preservation and Access $141,821
19.040 Public Diplomacy Programs $141,304
93.361 Nursing Research $139,417
12.600 Community Investment $138,080
10.351 Rural Business Development Grant $136,489
93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services $136,012
11.012 Integrated Ocean Observing System (ioos) $133,835
47.083 Integrative Activities $126,387
93.233 National Center on Sleep Disorders Research $124,592
16.U01 Contracts - Department of Justice $123,567
93.393 Cancer Cause and Prevention Research $120,445
93.113 Environmental Health $112,679
10.565 Commodity Supplemental Food Program $103,294
15.634 State Wildlife Grants $102,227
93.665 Emergency Grants to Address Mental and Substance Use Disorders During Covid-19 $101,663
43.RD Contract - NASA Blanket for Cooperative Agreements $100,316
66.708 Pollution Prevention Grants Program $100,187
21.U01 Contracts - Department of the Treasury $100,162
47.070 Computer and Information Science and Engineering $99,856
16.738 Edward Byrne Memorial Justice Assistance Grant Program $98,003
84.161 Rehabilitation Services Client Assistance Program $96,656
12.002 Procurement Technical Assistance for Business Firms $94,259
93.866 Aging Research $93,210
43.008 Office of Stem Engagement (ostem) $92,772
23.RD Contracts - Appalachian Regional Commission $92,660
93.618 Voting Access for Individuals with Disabilities-Grants for Protection and Advocacy Systems $91,444
81.086 Conservation Research and Development $84,141
12.300 Basic and Applied Scientific Research $80,288
39.003 Donation of Federal Surplus Personal Property $79,894
93.350 National Center for Advancing Translational Sciences $73,829
81.049 Office of Science Financial Assistance Program $72,976
93.839 Blood Diseases and Resources Research $69,901
20.237 Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements $69,320
93.873 State Grants for Protection and Advocacy Services $69,132
93.843 Acl Assistive Technology State Grants for Protection and Advocacy $68,023
10.766 Community Facilities Loans and Grants $66,696
93.859 Biomedical Research and Research Training $65,839
93.600 Head Start $64,110
17.502 Occupational Safety and Health Susan Harwood Training Grants $61,110
93.426 The National Cardiovascular Health Program $60,394
12.800 Air Force Defense Research Sciences Program $59,994
17.268 H-1b Job Training Grants $57,226
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $56,822
15.506 Water Desalination Research and Development $56,420
45.312 National Leadership Grants $53,735
62.RD Contracts - Tva $51,204
97.061 Centers for Homeland Security $49,840
10.217 Higher Education - Institution Challenge Grants Program $48,339
81.121 Nuclear Energy Research, Development and Demonstration $48,307
81.RD Contracts - Department of Energy $47,378
17.603 Brookwood-Sago Grant $46,812
64.055 Staff Sergeant Parker Gordon Fox Suicide Prevention Grant Program $45,825
93.121 Oral Diseases and Disorders Research $45,685
93.838 Lung Diseases Research $45,517
12.420 Military Medical Research and Development $45,211
81.089 Fossil Energy Research and Development $44,438
16.839 Stop School Violence $43,722
11.420 Coastal Zone Management Estuarine Research Reserves $43,238
10.164 Wholesale Farmers and Alternative Market Development $41,441
10.310 Agriculture and Food Research Initiative (afri) $40,248
21.015 Resources and Ecosystems Sustainability, Tourist Opportunities, and Revived Economies of the Gulf Coast States $39,312
10.212 Small Business Innovation Research $38,138
93.630 Developmental Disabilities Basic Support and Advocacy Grants $37,418
66.701 Toxic Substances Compliance Monitoring Cooperative Agreements $36,398
17.285 Registered Apprenticeship $35,632
15.808 U.s. Geological Survey Research and Data Collection $33,938
43.003 Exploration $33,549
15.805 Assistance to State Water Resources Research Institutes $33,383
93.RD Contracts - Department of Health and Human Services $31,203
43.009 Mission Support $30,675
20.RD Covid-19 Contracts - Department of Transportation $29,549
84.324 Research in Special Education $29,234
47.079 Office of International Science and Engineering $28,861
43.012 Space Technology $28,689
16.754 Harold Rogers Prescription Drug Monitoring Program $28,524
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $28,457
93.434 Every Student Succeeds Act/preschool Development Grants $26,965
11.459 Weather and Air Quality Research $26,913
43.001 Science $26,279
59.037 Covid-19 Small Business Development Centers $25,968
10.558 Child and Adult Care Food Program $25,579
66.516 P3 Award: National Student Design Competition for Sustainability $24,952
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $23,567
14.RD Contracts - Department of Housing and Urban Development $21,421
47.049 Mathematical and Physical Sciences $19,366
81.087 Renewable Energy Research and Development $18,878
93.191 Graduate Psychology Education $18,560
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $18,023
15.946 Cultural Resources Management $17,602
84.181 Special Education-Grants for Infants and Families $17,505
93.865 Child Health and Human Development Extramural Research $17,000
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $16,651
96.007 Social Security Research and Demonstration $16,554
93.048 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $16,503
11.431 Climate and Atmospheric Research $15,935
20.200 Highway Research and Development Program $15,534
93.110 Maternal and Child Health Federal Consolidated Programs $14,955
11.405 Cooperative Institute (inter-Agency Funded Activities) $14,449
45.169 Promotion of the Humanities Office of Digital Humanities $14,398
19.501 Public Diplomacy Programs for Afghanistan and Pakistan $13,634
20.205 Highway Planning and Construction $13,530
15.810 National Cooperative Geologic Mapping $13,350
84.425 Covid-19 Education Stabilization Fund $13,251
66.475 Geographic Programs – Gulf of Mexico Program $12,399
93.213 Research and Training in Complementary and Integrative Health $11,817
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $11,776
47.RD Contracts - National Science Foundation $10,154
15.615 Cooperative Endangered Species Conservation Fund $9,797
15.424 Marine Minerals Activities $9,620
42.010 Teaching with Primary Sources $9,235
47.074 Biological Sciences $8,550
84.063 Federal Pell Grant Program $8,226
10.170 Specialty Crop Block Grant Program - Farm Bill $7,476
15.232 Joint Fire Science Program $7,296
19.019 International Programs to Combat Human Trafficking $6,927
93.967 Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health $6,448
84.305 Education Research, Development and Dissemination $6,043
47.050 Geosciences $5,772
93.242 Mental Health Research Grants $5,750
93.395 Cancer Treatment Research $5,498
93.636 Contracts - Department of Health and Human Services $5,023
47.041 Engineering $4,167
66.RD Contracts - Environmental Protection Agency $4,095
47.075 Social, Behavioral, and Economic Sciences $3,840
47.076 Stem Education (formerly Education and Human Resources) $3,773
15.252 Abandoned Mine Land Reclamation (amlr) $2,966
15.RD Contracts - Department of Interior $2,931
10.RD Contracts - Department of Agriculture $2,590
15.631 Partners for Fish and Wildlife $2,036
15.663 Nfwf-Usfws Conservation Partnership $1,996
12.114 Collaborative Research and Development $1,733
93.226 Research on Healthcare Costs, Quality and Outcomes $1,646
97.RD Department of Homeland Security $1,535
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $1,464
16.RD Contracts - Department of Justice $1,180
89.003 National Historical Publications and Records Grants $1,027
45.301 Museums for America $1,019
45.024 Promotion of the Arts Grants to Organizations and Individuals $970
84.033 Federal Work-Study Program $560
15.657 Endangered Species Recovery Implementation $413
11.417 Sea Grant Support $258
20.RD Contracts - Department of Transportation $190
12.RD Contracts - Department of Defense $187
17.RD Contracts - Department of Labor $130
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $54
16.585 Treatment Court Discretionary Grant Program $-1
93.855 Allergy and Infectious Diseases Research $-811
93.816 Preventing Heart Attacks and Strokes in High Need Areas $-3,217
81.135 Advanced Research Projects Agency - Energy $-8,608
93.779 Centers for Medicare and Medicaid Services (cms) Research, Demonstrations and Evaluations $-9,968