Finding 509610 (2024-006)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-11-20
Audit: 329180
Organization: Concordia University, St. Paul (MN)

AI Summary

  • Core Issue: The University failed to perform required due diligence on its third-party servicer for the Perkins Loan program due to a delay in the compliance audit report.
  • Impacted Requirements: Compliance with 2 CFR 200.303 and related federal regulations regarding internal controls and due diligence on third-party servicers.
  • Recommended Follow-Up: Establish a procedure with the servicer to ensure timely completion of the Title IV compliance report for future audits.

Finding Text

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.038 – Federal Perkins Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: 2 CFR 200.303 Code of Federal Regulations Title 34, Subtitle B, Chapter VI, Part 674.19 requires that in administering its Federal Perkins Loan program, an institution shall establish and maintain an internal control system of checks and balances that ensures that no office can both authorize payments and disburse funds to students. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Such due diligence could include obtaining and reviewing the third-party servicer’s most recent Title IV compliance audit. Condition: The University utilizes a third party service provider for its Perkins Loan servicing. Federal regulations require the institution to perform due diligence on the third party servicer to ensure they are following federal regulations. The institution was not able to perform their due diligence for fiscal year 2024 since the third party service provider’s 2024 Title IV compliance audit was not completed as of issuance of audit. Questioned Costs: None Context: The due diligence typically performed by the institution is the review of the third party servicer's compliance report. However, the third party servicer was delayed in having this report issued. The institution did not have an alternate plan for performing due diligence over the third party servicer. Cause: The third party servicer, did not have their Title IV compliance audit report completed for the year ending June 30, 2024 so that the University could perform their required due diligence on the third party servicer and the institution did not have an alternate plan established. Effect: The University did not perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Repeat Finding: Yes Auditors’ Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their Title IV compliance report is completed timely so that the University can perform the necessary due diligence they need to perform. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Assistance Cluster– 84.038 – Federal Perkins Loans Recommendation: We recommend that the University implement a procedure with the third-party servicer to ensure that its Title IV compliance report is completed in a timely manner so that the University can perform the necessary due diligence. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: For 22-23, the third-party servicer provided the compliance report in March 2024. For 23-24, the third-party servicer states the report should be available by the end of December 2024. Name(s) of the contact person(s) responsible for corrective action: Michael Dorner Planned completion date for corrective action plan: Already in place

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Significant Deficiency

Other Findings in this Audit

  • 509588 2024-001
    Significant Deficiency Repeat
  • 509589 2024-001
    Significant Deficiency Repeat
  • 509590 2024-001
    Significant Deficiency Repeat
  • 509591 2024-001
    Significant Deficiency Repeat
  • 509592 2024-001
    Significant Deficiency Repeat
  • 509593 2024-001
    Significant Deficiency Repeat
  • 509594 2024-002
    Significant Deficiency Repeat
  • 509595 2024-002
    Significant Deficiency Repeat
  • 509596 2024-002
    Significant Deficiency Repeat
  • 509597 2024-002
    Significant Deficiency Repeat
  • 509598 2024-002
    Significant Deficiency Repeat
  • 509599 2024-002
    Significant Deficiency Repeat
  • 509600 2024-003
    Significant Deficiency
  • 509601 2024-003
    Significant Deficiency
  • 509602 2024-003
    Significant Deficiency
  • 509603 2024-004
    Significant Deficiency
  • 509604 2024-004
    Significant Deficiency
  • 509605 2024-004
    Significant Deficiency
  • 509606 2024-004
    Significant Deficiency
  • 509607 2024-004
    Significant Deficiency
  • 509608 2024-004
    Significant Deficiency
  • 509609 2024-005
    Significant Deficiency Repeat
  • 1086030 2024-001
    Significant Deficiency Repeat
  • 1086031 2024-001
    Significant Deficiency Repeat
  • 1086032 2024-001
    Significant Deficiency Repeat
  • 1086033 2024-001
    Significant Deficiency Repeat
  • 1086034 2024-001
    Significant Deficiency Repeat
  • 1086035 2024-001
    Significant Deficiency Repeat
  • 1086036 2024-002
    Significant Deficiency Repeat
  • 1086037 2024-002
    Significant Deficiency Repeat
  • 1086038 2024-002
    Significant Deficiency Repeat
  • 1086039 2024-002
    Significant Deficiency Repeat
  • 1086040 2024-002
    Significant Deficiency Repeat
  • 1086041 2024-002
    Significant Deficiency Repeat
  • 1086042 2024-003
    Significant Deficiency
  • 1086043 2024-003
    Significant Deficiency
  • 1086044 2024-003
    Significant Deficiency
  • 1086045 2024-004
    Significant Deficiency
  • 1086046 2024-004
    Significant Deficiency
  • 1086047 2024-004
    Significant Deficiency
  • 1086048 2024-004
    Significant Deficiency
  • 1086049 2024-004
    Significant Deficiency
  • 1086050 2024-004
    Significant Deficiency
  • 1086051 2024-005
    Significant Deficiency Repeat
  • 1086052 2024-006
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $33.89M
84.063 Federal Pell Grant Program $6.17M
84.038 Federal Perkins Loans $482,795
84.007 Federal Supplemental Educational Opportunity Grants $289,602
84.033 Federal Work-Study Program $133,000
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $76,544