Finding 40153 (2022-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-07-12
Audit: 53516
Organization: Virginia Union University (VA)
Auditor: Brown Edwards

AI Summary

  • Core Issue: The University failed to properly reconcile Direct Loan disbursements, resulting in over $1.2 million in funds not being processed through the Department of Education.
  • Impacted Requirements: Monthly reconciliation of Direct Loan records is required by the Department of Education, and the current process is insufficient to identify discrepancies at the student level.
  • Recommended Follow-Up: Enhance the reconciliation process by ensuring collaboration between financial aid and business offices, conduct monthly reconciliations, and address any discrepancies promptly to maintain compliance.

Finding Text

Criteria: Institutions are required to report all Direct Loan (DL) disbursements and submit required records to the Department of Education?s Common Origination and Disbursement (COD) which is a web-based system for processing, storing, and reconciling DL financial aid data. 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 school) Loan Detail records. The school is required to reconcile these files to the Institution?s financial records (?DL Reconciliations?). The University completed a reconciliation at the student level for FY20 and FY21 as part of the audit process and noted $708,695 and $561,172 of direct loan funds that had been posted to student accounts but, did not appear on the student?s COD indicating that a total of $1,269,867 had not been properly processed by the University through the Department of Education and as such, the University had not received these funds to apply to the amounts awarded to student accounts (reimburse the University). To the extent that these issues were corrected, they were reported in the current year SEFA. However, significant issues were still encountered during the FY22 financial statement audit with reconciling direct student loans that resulted in audit adjustments and a passed / unrecorded audit adjustment for the amount that remained unreconciled at the end of FY22 and its financial statement audit completion. Condition: We tested the University?s monthly DL Reconciliation workpaper and noted that the design of the reconciliation process was not sufficient to determine reconciling items at a student level. Cause: The design of the University?s DL Reconciliations appeared to not include determining reconciling items at the student level. Effect: Due to the insufficient DL Reconciliation process, it is likely that the Institution could potentially miss detecting and correcting certain issues or instances of noncompliance in a timely manner. Questioned costs: $-0- Perspective information: The Department of Education requires institutions to reconcile the Direct Loan Program monthly. Identification of repeat findings: Yes, see FA-2021-001. Recommendation: We recommend that the DL Reconciliation process include cooperation between the business and financial aid offices given the financial aid office is the source of information reported to and from COD, and the business office is responsible for the drawdown of funds from the Department of Education?s G5 website as well as for disbursing DL funds to student accounts. At a minimum, the frequency of the DL Reconciliation must be monthly to meet compliance requirements. The financial aid and business offices should first perform an internal reconciliation of their records, identifying any reconciling items at a detailed (student) level. Once this internal reconciliation is complete, the University should perform the external reconciliation to COD?s records via the SAS data file, identifying any reconciling items at a detailed level. Reconciling items from both the internal and external reconciliations should be evaluated for items that require corrective action(s). Corrective actions should be taken timely to correct any issues identified by this process. Finally, cumulative data in G5, such as net drawdowns and net accepted and posted disbursements, should be incorporated into the reconciliation to ensure the University is in compliance with Department of Education?s Cash Management requirements. Further, as a result of the University performing a complete reconciliation for FY20 and FY21, the University should request that the Department of Education provide access to these years that are currently closed so that they can make the corrections required to complete the processing of the student awards not previously properly processed. Views of responsible officials: The University should retain these reconciliations, including all supporting documentation, for purposes of internal and/or external examination. See Client?s Corrective Action Plan.

Corrective Action Plan

See corrective action plan for chart/table.

Categories

Student Financial Aid Cash Management Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 40152 2022-004
    Material Weakness
  • 40154 2022-002
    Significant Deficiency Repeat
  • 40155 2022-003
    Significant Deficiency Repeat
  • 42658 2022-005
    Material Weakness
  • 42659 2022-006
    Material Weakness
  • 42660 2022-007
    Material Weakness
  • 616594 2022-004
    Material Weakness
  • 616595 2022-001
    Material Weakness Repeat
  • 616596 2022-002
    Significant Deficiency Repeat
  • 616597 2022-003
    Significant Deficiency Repeat
  • 619100 2022-005
    Material Weakness
  • 619101 2022-006
    Material Weakness
  • 619102 2022-007
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $7.62M
84.425 Education Stabilization Fund $4.90M
84.063 Federal Pell Grant Program $3.50M
47.076 Education and Human Resources $451,395
84.007 Federal Supplemental Educational Opportunity Grants $390,500
84.031 Higher Education_institutional Aid $380,517
84.047 Trio_upward Bound $331,351
84.042 Trio_student Support Services $308,503
84.033 Federal Work-Study Program $238,349
84.044 Trio_talent Search $194,307
99.U01 National Institue of General Medical Sciences: Institutional Research and Academic Career Devleopment Awards $26,303