Finding 519538 (2024-003)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-01-17
Audit: 338574
Organization: Life University, Inc. (GA)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The University failed to report a student's Direct Loan disbursement to the COD within the required 15-day timeframe.
  • Impacted Requirements: This non-compliance with federal regulations could lead to potential penalties or loss of funding.
  • Recommended Follow-Up: Implement procedures to ensure timely reporting of student status changes and utilize the Anticipated Disbursement Queue report every 14 days to catch issues early.

Finding Text

Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Disbursement to or on Behalf of Students: Federal regulation 88 FR 41092 states an institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Condition: The University did not report student’s direct loan disbursement to the COD within the required timeframe. Cause: Administrative oversight. Effect or Possible Effect: The University was not in compliance with required federal guidelines. Questioned Costs: None. Context: Direct Loan COD disbursement: Based on a sample of 25 Direct loan disbursements tested, 1 instance of a student’s Direct Loan disbursement was not reported to COD within 15 days as required. Identification of Repeat Finding: This is a new finding for FY2024. Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner. Views of Responsible Officials: After speaking with a Common Origination and Disbursement (COD) system representative, she stated that schools will receive a Warning Edit 055 when record of disbursement has not been received after 30 days. She verified that we did not receive this Warning Edit 055 from COD because we had not exceeded 30 days. The COD rep went on to share that this 15-day regulation used to be a 30-day regulation, but COD has not updated their Warning Edit 055 process to notify schools. It’s only done after 30 days. COD rep did identify a report Michelle will run to identify anyone who is not showing up with a disbursement record prior to the 15 days. The COD report is called the Anticipated Disbursement Queue and will be ran every 14 days to identify any potential issues.

Corrective Action Plan

Individuals Responsible for Corrective Action Plan: Michelle Nixon- Assistant Director of Financial Aid Systems. Melissa Waters- Senior Director of Student Administration and Compliance Condition: Finding related to disbursement record to Common Origination and Disbursement (COD) system in excess of 15 days This student’s disbursement occurred on 10/2/23 and LU verified that a disbursement record was sent to COD on 10/2/23; however, this student was not included in that record. We are unable to determine why the student was not included in that disbursement record. We send up disbursement records to COD 3 times a week. The student’s disbursement was transmitted to COD on 10/20/23. Management’s Corrective Action Plan: After speaking with a Common Originations and Disbursement (COD system representative, she stated that schools will receive a Warning Edit 055 when record of disbursement has not been received after 30 days. She verified that we did not receive this Warning Edit 055 from COD because we had not exceeded 30 days. The COD rep went on to share that this 15-day regulation used to be a 30-day regulation, but COD has not updated their Warning Edit 055 process to notify schools. It’s only done after 30 days. COD rep did identify a report Michelle will run to identify anyone who is not showing up with a disbursement record prior to the 15 days. The COD report is called the Anticipated Disbursement Queue and will be ran every 14 days to identify any potential issues. Anticipated Completion Date: January 1st, 2025

Categories

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 519534 2024-002
    Significant Deficiency
  • 519535 2024-002
    Significant Deficiency
  • 519536 2024-002
    Significant Deficiency
  • 519537 2024-002
    Significant Deficiency
  • 519539 2024-004
    Significant Deficiency
  • 1095976 2024-002
    Significant Deficiency
  • 1095977 2024-002
    Significant Deficiency
  • 1095978 2024-002
    Significant Deficiency
  • 1095979 2024-002
    Significant Deficiency
  • 1095980 2024-003
    Significant Deficiency
  • 1095981 2024-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $106.23M
84.063 Federal Pell Grant Program $2.28M
84.033 Federal Work-Study Program $860,219
84.007 Federal Supplemental Educational Opportunity Grants $248,363
84.038 Federal Perkins Loans $0