Finding 51858 (2022-004)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-29
Audit: 43164
Organization: American Jewish University (CA)
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: The University failed to report a status change for a graduated student to the NSLDS, violating federal requirements.
  • Impacted Requirements: Compliance with 34 CFR section 685.309(b)(2)(i) regarding timely notification of enrollment status changes.
  • Recommended Follow-Up: Implement cross-training protocols to ensure timely reporting and reduce reliance on individual staff members.

Finding Text

FINDING 2022-004?Special Tests and Provisions?Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "See Schedule of Findings and Questioned Costs for chart/table." Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/context ? A sample of 3 federal aid recipient students was selected from reports of students who graduated during the 2021-2022 academic year. There were no students who withdrew or dropped during the 2021-2022 academic year. The enrollment information and withdrawal or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the status change of 1 graduated student selected for testing was not reported to the NSLDS. Cause ? Due to turnover in the position responsible for performing the manual reporting process, reporting was not completed until the responsibility was assigned to a new employee. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat finding ? This is a repeat finding. See 2021-005. Recommendation ? We recommend the University revise its policies to establish cross-training protocols for responsibilities that contain strict deadlines. Views of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters.

Corrective Action Plan

FINDING 2022-004 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Condition/context: An exception was noted whereby the status change of 1 graduated student selected for testing was not reported to the NSLDS. Cause: Due to turnover in the position responsible for performing the manual reporting process reporting was completed when the responsibility was assigned to a new employee. Corrective Action Plan: Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters. Responsible person: Sarah Stooksberry / Cindy Farrington Planned completion date: Completed as of the date of this letter.

Categories

Student Financial Aid Reporting Significant Deficiency Matching / Level of Effort / Earmarking Special Tests & Provisions Internal Control / Segregation of Duties

Other Findings in this Audit

  • 51856 2022-001
    Significant Deficiency
  • 51857 2022-003
    Significant Deficiency Repeat
  • 51859 2022-001
    Significant Deficiency
  • 51860 2022-003
    Significant Deficiency Repeat
  • 51861 2022-004
    Significant Deficiency Repeat
  • 51862 2022-001
    Significant Deficiency
  • 51863 2022-003
    Significant Deficiency Repeat
  • 51864 2022-004
    Significant Deficiency Repeat
  • 51865 2022-001
    Significant Deficiency
  • 51866 2022-002
    Material Weakness Repeat
  • 51867 2022-003
    Significant Deficiency Repeat
  • 51868 2022-004
    Significant Deficiency Repeat
  • 628298 2022-001
    Significant Deficiency
  • 628299 2022-003
    Significant Deficiency Repeat
  • 628300 2022-004
    Significant Deficiency Repeat
  • 628301 2022-001
    Significant Deficiency
  • 628302 2022-003
    Significant Deficiency Repeat
  • 628303 2022-004
    Significant Deficiency Repeat
  • 628304 2022-001
    Significant Deficiency
  • 628305 2022-003
    Significant Deficiency Repeat
  • 628306 2022-004
    Significant Deficiency Repeat
  • 628307 2022-001
    Significant Deficiency
  • 628308 2022-002
    Material Weakness Repeat
  • 628309 2022-003
    Significant Deficiency Repeat
  • 628310 2022-004
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $768,335
84.425 Higher Education Emergency Relief Fund $151,000
84.063 Federal Pell Grant Program $24,030
84.007 Federal Supplemental Educational Opportunity Grants Program $23,010
84.033 Federal Work Study Program $19,601