Finding 520054 (2024-001)

-
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-01-23

AI Summary

  • Core Issue: A student exceeded the $23,000 loan limit for Direct Subsidized Loans due to inadequate internal controls.
  • Impacted Requirements: Compliance with 34 CFR 685.023 Loan Limits was not maintained, affecting federal loan disbursement regulations.
  • Recommended Follow-Up: Strengthen internal controls to monitor loan awards, especially for transfer and fourth-year students nearing the limit.

Finding Text

Program: Federal Direct Student Loans CFDA 84.268 Criteria: Per 34 Code of Federal Regulations ("CFR") 685.023 Loan Limits, the aggregate unpaid principal amount of all Direct Subsidized Loans made to a student may not exceed $23,000 for a student who has not successfully completed a program of study at the undergraduate level. Condition: The College's internal controls surrounding the disbursement of Federal Direct Student Loans to students were not adequate to maintain compliance with Title IV regulations. Repeat Finding from Prior Year: No Questioned Cost: None Context: Out of the 40 students tested, one student's aggregate unpaid principal amount of all Direct Subsidized Loans exceeded the $23,000 loan limit. Effect: Cleveland Institute of Art did not meet the requirement of ensuring that the student's aggregate borrowing of Direct Subsidized Loans was within the borrowing limitations established per CFR 685.023 Loan Limits. Cause: The overpayment identified is due to a transfer student's Direct Subsidized Loan history not being adequately reviewed. Recommendation: Implement a system of internal controls to closely monitor the awarding of Direct Subsidized Loans to transfer students and fourth year students whose aggregate borrowings are close to limit. Management Response: Management acknowledges that there was an error in the amount of Direct Subsidized Loan awarded to the student. The College reviewed all aggregate Direct Subsidized Loan awards for 2023-2024 and noted this was an isolated incident. The College is also strengthening its internal controls around monitoring ISIR comment codes 255, 256, 258, 260 and 261 on a continual basis during packaging season to look for any potential over awards and to pay close attention to transfer students and fourth year student loan limits, and to monitor subsequent ISIR transactions for NSLDS post-screenings.

Corrective Action Plan

Management acknowledges that there was an error with one over award of subsidized loan on a student. Student was given $448 (gross) over the aggregate subsidized limit. The overage was sent back to the Direct lender. Since the student graduated, the $448 was covered by a grant. A survey of all students was completed and no other students were discovered to have been over their aggregate subsidized limit. • A student’s aggregate subsidized amount on NSLDS from his FAFSA record was listed at $17,948, allowing only $5,052 in remaining to reach the $23,000 aggregate limit on subsidized loan. Student was given $5,500 when it should have been $5,052. The $448 should have been given as unsubsidized loan. Student had previous loans from another school. (Powerfaids will catch this error if all of the historic loans were processed within our database.) • The student ISIR record did have Comment code 258: “Based upon data provided by the National Student Loan Data System (NSLDS) and your grade level, we have determined that you may have received a total amount of undergraduate student loans that is close to or equal to the loan limits established for the federal loan programs. Therefore, your eligibility for additional student loans may be limited.“ • The Federal processor usually sends a post-screening after federal aid is disbursed with warnings of limits: 255, 256, 258. 260 ad 261. This would cause a C-code on the student record. We did not receive a subsequent ISIR record on said student. Corrective Action Plan: Include in the Quality Assurance rules one for the ISIR codes associated with NSLDS overawarding of loans whether it be annual limits or aggregate limits. We will monitor these codes regularly during packaging season and subsequent to loan disbursing.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Subrecipient Monitoring

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $6.16M
84.063 Federal Pell Grant Program $1.43M
84.038 Federal Perkins Loan Program $878,920
84.033 Federal Work-Study Program $161,501
84.007 Federal Supplemental Educational Opportunity Grants $94,983