Finding Text
2024-002 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Borrower Data and Reconciliation
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria: Each month, the Common Origination and Disbursement (COD) system 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.
Condition: The SAS reconciliations were not performed during the year.Cause: The University did not have internal controls to provide for the reconciliations of the SAS
data file.
Effect: Records maintained by the COD may not agree to the University’s records.
Questioned Costs: None reported.
Context/Sampling: The SAS monthly reconciliations were not performed for the whole year.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the University implement internal controls to provide for the
reconciliation of the SAS data file.
Views of Responsible Officials: Management agrees with the finding.