Finding 513129 (2024-001)

Significant Deficiency
Requirement
E
Questioned Costs
$1
Year
2024
Accepted
2024-12-05
Audit: 331120
Organization: University of Western States (OR)
Auditor: Rsm US LLP

AI Summary

  • Core Issue: Six students in the Doctor of Naturopathic Medicine program were overawarded Federal Direct Unsubsidized Loans, totaling $119,443, exceeding the maximum allowable amount of $20,500.
  • Impacted Requirements: The awards violated federal regulations regarding loan limits for graduate students, as the program lacks the necessary accreditation for higher loan amounts.
  • Recommended Follow-Up: UWS should enhance internal controls to ensure compliance with financial aid award limits and prevent future overawards.

Finding Text

Finding 2024-001: Eligibility – Determining Federal Direct Student Loan Awards Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster, Federal Direct Student Loans Assistance Listing Number: 84.268 Award Year: June 1, 2023 – May 31, 2024 Program Expenditures: $20,593,109 Questioned Costs: $119,443 Criteria: Per 34 CFR 685.203(b)(iii), in the case of a graduate or professional student for a period of enrollment beginning on or after July 1, 2012, the total amount the student may borrow for any academic year of study under the Unsubsidized Loan program may not exceed $8,500. Per 34 CFR 685.203(c)(2)(v), the additional amount that a student described in paragraph (c)(1)(i) of this section may borrow under the Federal Direct Unsubsidized Loan Program for any academic year of student may not exceed the following: in the case of a graduate or professional student, $12,000. Condition: During testing of eligibility, six out six students selected for testing within the Doctor of Naturopathic Program were overawarded Federal Direct Unsubsidized Loans, noting this encompasses all students within the program. Eligibility testing was performed over 40 other students with no exceptions. We determined that UWS improperly awarded 6 out of 6 students Federal Direct Unsubsidized Loans in excess of the maximum amount for one academic year of $20,500. The total overawards accumulated to $119,443 in total loan funds. Cause: The students were awarded the higher annual Federal Direct Unsubsidized Loan limits for certain graduate and professional health professions students. Schools may award the increased unsubsidized amounts to students who are enrolled at least half time in certain health professions programs. The programs must be accredited by specific accrediting agencies for students to qualify for additional unsubsidized loan amounts. The UWS Naturopathic Medicine Doctoral program has not yet achieved the required accreditation from The Council on Naturopathic Medical Education. Effect: UWS is required to return overawarded funds to the Department of Education in accordance with Department guidelines. Noncompliance with federal guidelines could impact future funding. Questioned Costs: $119,443 Context: Six out six students subject to eligibility testing within the Doctor of Naturopathic Medicine program were overawarded Federal Direct Unsubsidized Loans in excess of the maximum allowed amount of $20,500 for an academic period. Eligibility testing was performed over forty other students with no errors. Management detected the overaward subsequent to year-end, but prior to the start of the audit and informed RSM of the error. Repeat Finding: No. Recommendation: We recommend UWS strengthen internal controls around the establishing of financial aid award limits. Views of Responsible Officials: Management agrees with the finding. Please see corrective action plan attached.

Corrective Action Plan

Identifying Number: 2024-0001 Finding: Eligibility – Determining Federal Direct Student Loan Awards Applicable Regulation: Per 34 CFR 685.203(b)(iii), in the case of a graduate or professional student for a period of enrollment beginning on or after July 1, 2012, the total amount the student may borrow for any academic year of study under the Unsubsidized Loan program may not exceed $8,500. Per 34 CFR 685.203(c)(2)(v), the additional amount that a student described in paragraph (c)(1)(i) of this section may borrow under the Direct Unsubsidized Loan Program for any academic year of student may not exceed the following: in the case of a graduate or professional student, $12,000. Finding: UWS improperly awarded 6 out of 6 students Unsubsidized Federal Direct Loans in excess of the maximum amount for one academic year of $20,500. Summary: During testing of eligibility, six out six students selected for testing within the Doctor of Naturopathic Program were overawarded Unsubsidized Federal Direct Loans. Eligibility testing was performed over 40 other students with no exceptions. We determined that UWS improperly awarded 6 out of 6 students Unsubsidized Federal Direct Loans in excess of the maximum amount for one academic year of $20,500. The total overawards accumulated to $119,443 in total loan funds. The students were awarded the higher annual Direct Unsubsidized Loan limits for certain graduate and professional health professions students. Schools may award the increased unsubsidized amounts to students who are enrolled at least half time in certain health professions programs. The programs must be accredited by specific accrediting agencies for students to qualify for additional unsubsidized loan amounts. The UWS Naturopathic Medicine Doctoral program has not yet achieved the required accreditation from The Council on Naturopathic Medical Education Corrective Action Planned or Taken: During the course of an internal audit of student awards in the Naturopathic Medicine Doctoral program it was determined that the required programmatic accreditation had not been achieved from the Council on Naturopathic Medical Education to qualify for the additional Health Professions unsubsidized loan eligibility. As a result of this finding a thorough audit was completed for all students that were enrolled in the program since the first class began in October of 2023. In total six students were identified, and awards were adjusted to the proper annual loan limit of $20,500. The Institution made students whole by forgiving any student balances that would have been paid by theover award amount. In addition, the software configuration was changed to ensure moving forward that students receive up to the proper maximum of $20,500 until proper accreditation is achieved. Contact Person: Michelle Miller, Senior Vice President of Enrollment Management mmiller10@tcsedsystem.edu Anticipated Completion Date: September 13, 2024

Categories

Questioned Costs Eligibility Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 513130 2024-002
    Significant Deficiency
  • 1089571 2024-001
    Significant Deficiency
  • 1089572 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $20.59M
84.038 Federal Perkins Loans Program $771,994
84.033 Federal Work-Study Program $56,085