Finding Text
2024-009
8565.02
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by an institution participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. An institution must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
The University did not have documentation that Direct Loan Reconciliation prepared by third-party servicer was reviewed.
N/A
During our testing we examined four months of direct loan reconciliations (August, December, March, & May). For all four, the University's third party servicer (Campus Ivy) performed preparation and review of the reconciliation; however, Urshan did not review the work of Campus Ivy or a SOC1 report.
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements.
No
We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Management agrees with this finding.
See 0100.25