Finding 575951 (2024-001)

Significant Deficiency
Requirement
N
Questioned Costs
$1
Year
2024
Accepted
2025-09-09

AI Summary

  • Core Issue: There is a significant deficiency in compliance with federal regulations regarding disbursement dates for student loans.
  • Impacted Requirements: Disbursement records must be submitted within 15 days and accurately reflect the loan origination date as per Title IV regulations.
  • Recommended Follow-Up: Implement policies and controls to ensure disbursement dates are accurately reported and verified against the COD system.

Finding Text

Finding 2024-001: Significant Deficiency – Noncompliance with Special Tests and Provisions: Disbursements Federal Program - Student Financial Assistance Cluster Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable Assistance Listing Number - 84.268 Federal Award Number - P268K255904 Federal Award Year - December 31, 2024 Criteria: Title IV regulations (34 CFR 685.301(b)(6)) require that the date of loan origination is the date a school creates the electronic loan origination record. Title IV regulations specifies that a school must submit disbursement records no later than 15 days after making the disbursement or becoming aware of the need to adjust a student's previously reported disbursement. Institutions submit Direct Loan origination records and disbursement records to the Common Origination and Disbursement (COD) system. The disbursement record reports the actual disbursement date and the amount of the disbursement. The US Department of Education processes origination and/or disbursement records and returns acknowledgments to the institution. Condition: For 3 of 25 students selected for testing, the disbursement dates did not agree between the student's institutional account and the data reported to COD. Each student had disbursements that were later partially or fully refunded. The sample was not a statistically valid sample. Cause: The Foundation failed to follow its procedures for reporting student disbursement dates correctly and/or within the required timeframe. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the disbursement information reported by institutions. If an institution does not review, update, and verify disbursement dates, then the Title IV student loan records will be inaccurate. Questioned costs: $30,426 of Federal Direct Unsubsidized Loans. Recommendation: It is recommended that policies, procedures and effective controls are put in place to verify that the disbursement dates for federal funds are matching between the student account detail and the COD system. Management Response: The Foundation will ensure that policies, procedures and effective controls are in place to verify the matching of the disbursement dates for federal funds between the student account detail and the COD system.

Corrective Action Plan

Finding 2024-001: Non-compliance with Special Tests and Provisions: Disbursements Condition For 3 of 25 students selected for testing, the disbursement dates did not agree between the student’s institutional account and the data reported to COD. Each student had disbursements that were later partially or fully refunded. The sample was not a statistically valid sample. Recommendation It is recommended that policies, procedures and effective controls are put in place to verify that the disbursement dates for federal funds are matching between the student account detail and the COD system. Corrective Action The Foundation will ensure that policies, procedures and effective controls are in place to verify the matching of the disbursement dates for federal funds between the student account detail and the COD system. Anticipated completion date of implementing the corrective action plan will be immediate.

Categories

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions Subrecipient Monitoring Reporting Significant Deficiency

Other Findings in this Audit

  • 1152393 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $3.01M
93.279 Drug Use and Addiction Research Programs $17,568