Finding 42606 (2022-002)

Significant Deficiency
Requirement
N
Questioned Costs
$1
Year
2022
Accepted
2023-03-20
Audit: 38194

AI Summary

  • Core Issue: The College failed to perform mandatory monthly Direct Loan reconciliations, leading to errors in disbursements totaling $177,816.
  • Impacted Requirements: Non-compliance with Title IV regulations as outlined in 34 CFR 685.300(b)(5) due to inconsistent reconciliation processes.
  • Recommended Follow-Up: Review staffing and procedures to ensure timely reconciliations; implement regular oversight by management to maintain compliance.

Finding Text

Finding 2022-002: Significant Deficiency ? Direct Loan Reconciliation Program: Student Financial Assistance Cluster Assistance Listing Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K221186 Federal Award Year: June 30, 2022 Criteria: Title IV regulations note that Direct Loan reconciliation is a mandatory monthly process, as required under 34 CFR 685.300(b)(5). The U.S. Department of Education released an electronic announcement December 18, 2020 reminding institutions of this requirement. Each month, Common Origination and Disbursement (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. At a minimum, this reconciliation must be completed at least monthly to ensure that data is correct in all systems and that cash management and disbursement reporting timelines are being met. 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/Context: The College was not able to provide the three monthly reconciliations for November 2021, February 2022, or April 2022 when requested for the audit in the summer of 2022. The Institution noted that the reciliations had not been performed timely, and subsequently the Institution had a consultant complete these reconciliations. The auditors were unable to obtain evidence of or confirmation from the Institution regarding review of the reconciliations by someone other than the preparer occurred. The sample was not a statistically valid sample. Additionally, the College discovered that Direct Loan reconciliation hadn't been done correctly in the past due to staff turnover. A consultant was given the task of doing a complete 21-22 reconciliation in June 2022. This consultant discovered 16 students had been awarded $177,816 in error. The cause of this was that rules had not been setup correctly in Colleague, and consistent reconciliation by correcting Colleague and COD errors wasn't completed in a timely manner. The auditors obtained the listing of students awarded incorrectly. Cause: The College noted there was significant staffing issues/changes in key positions in the student financial aid office and business office and that resulted in the monthly reconciliations not being performed timely. Effect: The information in the College?s system or data reported to COD may be incorrect and not correctly timely if the monthly reconciliations are not occurring. Questioned costs: $177,816 of Federal Direct Loans assistance listing number 84.268. Recommendation: It is recommended that the College review staffing and policies and procedures to ensure that the monthly direct loan reconciliation is completed in a timely manner to facilitate compliance with Title IV regulations. Management?s Response: Management acknowledges the finding. For the $177,816 in direct loans incorrectly disbursed that was identified, the College returned the loans and replaced with institutional aid for the impacted students. The Assistant Director/Systems Specialist reconciles direct loans every month. The Executive Director of Financial Aid and the VP of Enrollment Management review these reports at the end of each month. In addition, a system adjustment has been set up for 2022-2023 to ensure reconciliation is done monthly. The Assistant Director/Systems Specialist utilizes Colleague variance reports that tracts Direct Loans disbursed year to date, the number that COD (Servicer for U.S. Department of Education) has approved, and the students that make up the variance, if any. In addition, COD and Colleague errors that occur during the import/export of Direct Loans to and from COD are corrected on a consistent basis. Reconciliation documentation is then forwarded to the Director for review.

Corrective Action Plan

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-002: Significant Deficiency ? Direct Loan Reconciliation Condition/Context: The College was not able to provide the three monthly reconciliations for November 2021, February 2022, or April 2022 when requested for the audit in the summer of 2022. The Institution noted that the reconciliations had not been performed timely, and subsequently the Institution had a consultant complete these reconciliations. The auditors were unable to obtain evidence of or confirmation from the Institution on if review of the reconciliations occurred. The sample was not a statistically valid sample. Additionally, the College discovered that Direct Loan reconciliation hadn't been done correctly in the past due to staff turnover. A consultant was given the task of doing a complete 21-22 reconciliation in June 2022. This consultant discovered 16 students had been awarded $177,816 in error. The cause of this was that rules had not been setup correctly in Colleague, and consistent reconciliation by correcting Colleague and COD errors wasn't completed in a timely manner. The auditors obtained the listing of students awarded incorrectly. Actions Taken: For the $177,816in direct loans incorrectly disbursed that was identified, SMC returned the loans and replaced with institutional aid for the impacted students. Beginning with July 2022, the Assistant Director/Systems Specialist reconciles direct loans every month. The Executive Director of Financial Aid and the VP of Enrollment Management review these reports at the end of each month. In addition, a system adjustment has been implemented for 2022-2023 to ensure reconciliation is done monthly. The Assistant Director/Systems Specialist utilizes Colleague variance reports that tract Direct Loans disbursed year to date, the number that COD (Servicer for U.S. Department of Education) has approved, and the students that make up the variance, if any. In addition, COD and Colleague errors that occur during the import/export of Direct Loans to and from COD are corrected on a consistent basis. Reconciliation documentation is then forwarded to the Executive Director for review. Name(s) of Contact Person Responsible for Corrective Action: Joseph Gilchrist, Interim Financial Aid Director Anticipated Completion date: June 30, 2023

Categories

Questioned Costs Student Financial Aid Cash Management Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 42590 2022-001
    Significant Deficiency Repeat
  • 42591 2022-003
    Significant Deficiency Repeat
  • 42592 2022-006
    Significant Deficiency
  • 42593 2022-001
    Significant Deficiency Repeat
  • 42594 2022-006
    Significant Deficiency
  • 42595 2022-001
    Significant Deficiency Repeat
  • 42596 2022-006
    Significant Deficiency
  • 42597 2022-001
    Significant Deficiency Repeat
  • 42598 2022-006
    Significant Deficiency
  • 42599 2022-005
    Significant Deficiency
  • 42600 2022-006
    Significant Deficiency
  • 42601 2022-005
    Significant Deficiency
  • 42602 2022-006
    Significant Deficiency
  • 42603 2022-005
    Significant Deficiency
  • 42604 2022-006
    Significant Deficiency
  • 42605 2022-001
    Significant Deficiency Repeat
  • 42607 2022-003
    Significant Deficiency Repeat
  • 42608 2022-004
    Significant Deficiency Repeat
  • 42609 2022-006
    Significant Deficiency
  • 619032 2022-001
    Significant Deficiency Repeat
  • 619033 2022-003
    Significant Deficiency Repeat
  • 619034 2022-006
    Significant Deficiency
  • 619035 2022-001
    Significant Deficiency Repeat
  • 619036 2022-006
    Significant Deficiency
  • 619037 2022-001
    Significant Deficiency Repeat
  • 619038 2022-006
    Significant Deficiency
  • 619039 2022-001
    Significant Deficiency Repeat
  • 619040 2022-006
    Significant Deficiency
  • 619041 2022-005
    Significant Deficiency
  • 619042 2022-006
    Significant Deficiency
  • 619043 2022-005
    Significant Deficiency
  • 619044 2022-006
    Significant Deficiency
  • 619045 2022-005
    Significant Deficiency
  • 619046 2022-006
    Significant Deficiency
  • 619047 2022-001
    Significant Deficiency Repeat
  • 619048 2022-002
    Significant Deficiency
  • 619049 2022-003
    Significant Deficiency Repeat
  • 619050 2022-004
    Significant Deficiency Repeat
  • 619051 2022-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $26.03M
84.063 Federal Pell Grant Program $2.45M
84.038 Federal Perkins Loan Program $1.38M
84.425 Education Stabilization Fund $711,111
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $525,446
47.074 Biological Sciences $522,585
84.033 Federal Work-Study Program $319,640
84.031 Higher Education_institutional Aid $223,488
84.042 Trio_student Support Services $220,781
47.076 Education and Human Resources $218,771
84.007 Federal Supplemental Educational Opportunity Grants $162,483
84.411 Investing in Innovation (i3) Fund $117,090
94.006 Americorps $108,360
94.013 Volunteers in Service to America $50,000
93.866 Aging Research $21,130
45.130 Promotion of the Humanities_challenge Grants $20,313
43.003 Exploration $15,456