FAC Explorer

Finding 592220 (2022-001)

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Requirement
L
Questioned Costs
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Year
2022
Accepted
2023-03-19
Audit: 18892
Organization: Trinity Health (MI)
Auditor: Deloitte & Touche LLP

AI Summary

  • Core Issue: Mount Carmel College of Nursing did not perform required monthly Direct Loan reconciliations, missing 12 reconciliations for the fiscal year.
  • Impacted Requirements: The College failed to comply with 34 CFR 685.300(b)(5) and Uniform Grant Guidance, risking unresolved discrepancies between financial aid and accounting records.
  • Recommended Follow-Up: The College should consult the Federal Student Aid Handbook to establish a compliant reconciliation process and implement controls to ensure timely resolution of discrepancies.

Finding Text

Condition ? Direct Loan reconciliation is a mandatory monthly process, as required under 34 CFR 685.300(b)(5). A school should reconcile all cash (drawdowns and refunds of cash) and disbursement records (actual disbursements and adjustments) with information in the Common Origination and Disbursement (COD) System on an ongoing basis. There are two types of reconciliation that can be performed separately or simultaneously during the month: 1) Internal Reconciliation - the business and financial aid offices compare the monthly financial aid office roster for scheduled and actual disbursements in each office?s system to a monthly business office cash detail report that reflects funds drawn down and funds disbursed each month;2) External Reconciliation ? Institutions compare their reconciled internal records to the Department of Education?s records of funds received and returned, and loans originated and disbursed. Mount Carmel College of Nursing (?the College?) performed monthly a reconciliation process only for loan disbursement records between the student financial aid system at the financial aid office and the Department?s COD System. It appears that the College failed to complete reconciliation for disbursement records within the student financial aid system at the financial aid office and the accounting system at the business office. Additionally, there was no reconciliation procedure performed for cash activities among the College?s student financial aid system, accounting system, and Department of Education?s COD System. Criteria ? The Uniform Grant Guidance Compliance Supplement Direct Loan Reconciliation requirement states, ?Each month, COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution?s financial records.? Cause ? The College?s student financial aid administration lacks understanding about the Direct Loan reconciliation process and knowledge about SAS data files. Effect ? The College failed to complete the monthly Direct Loan reconciliation in conformity with regulatory requirements. This potentially leads to the College not being able to timely identify and resolve discrepancies that exist among financial aid, business office, and COD records. Questioned costs ? None Context ? The College did not complete this requirement for the entire fiscal year, resulting in 12 reconciliations that were not performed. Repeat Finding from Prior Year ? No Recommendation ? The College?s Student Financial Aid administration shall consult with Direct Loan reconciliation regulatory guidance as illustrated in Federal Student Aid Handbook Volume 4 Chapter 6 and develop the monthly Direct Loan reconciliation process that is compatible with the College?s Direct Loan program operations. Additionally, respective controls shall be placed surrounding these processes to ensure that all records are reconciled, and discrepancies are resolved in a timely manner.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Cash Management

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund $437.80M
93.395 Cancer Treatment Research $3.31M
84.268 Federal Direct Student Loans $2.61M
93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services $1.74M
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.34M
93.261 National Diabetes Prevention Program: Preventing Type 2 Diabetes Among People at High Risk $1.32M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $490,305
93.650 Accountable Health Communities $482,098
93.461 Covid-19 Testing for the Uninsured $463,967
93.917 Hiv Care Formula Grants $435,824
93.575 Child Care and Development Block Grant $374,477
93.150 Projects for Assistance in Transition From Homelessness (path) $301,933
93.778 Medical Assistance Program $290,890
93.011 National Organizations of State and Local Officials $261,609
93.155 Rural Health Research Centers $252,916
93.074 Hospital Preparedness Program (hpp) and Public Health Emergency Preparedness (phep) Aligned Cooperative Agreements $242,581
93.914 Hiv Emergency Relief Project Grants $200,711
93.994 Maternal and Child Health Services Block Grant to the States $184,369
14.241 Housing Opportunities for Persons with Aids $180,053
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $171,404
84.063 Federal Pell Grant Program $156,515
93.667 Social Services Block Grant $152,319
14.231 Emergency Solutions Grant Program $150,000
93.604 Assistance for Torture Victims $136,091
93.276 Drug-Free Communities Support Program Grants $135,075
93.566 Refugee and Entrant Assistance_state Administered Programs $104,053
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $97,279
97.067 Homeland Security Grant Program $90,328
16.831 Children of Incarcerated Parents $87,219
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $83,971
93.268 Immunization Cooperative Agreements $75,730
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $67,246
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $66,697
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $65,746
16.575 Crime Victim Assistance $62,550
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $53,800
93.697 Covid-19 Testing for Rural Health Clinics $53,746
16.838 Comprehensive Opioid Abuse Site-Based Program $53,386
93.839 Blood Diseases and Resources Research $53,000
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $52,010
84.007 Federal Supplemental Educational Opportunity Grants $51,921
16.588 Violence Against Women Formula Grants $49,607
93.940 Hiv Prevention Activities_health Department Based $41,903
14.218 Community Development Block Grants/entitlement Grants $41,302
93.497 Family Violence Prevention and Services/ Sexual Assault/rape Crisis Services and Supports $40,665
93.889 National Bioterrorism Hospital Preparedness Program $40,000
93.958 Block Grants for Community Mental Health Services $34,798
93.364 Nursing Student Loans $24,541
10.558 Child and Adult Care Food Program $24,522
93.866 Aging Research $24,282
93.879 Medical Library Assistance $22,413
14.267 Continuum of Care Program $20,796
93.310 Trans-Nih Research Support $20,295
16.529 Education, Training, and Enhanced Services to End Violence Against and Abuse of Women with Disabilities $17,338
97.024 Emergency Food and Shelter National Board Program $12,500
93.247 Advanced Nursing Education Grant Program $12,348
93.301 Small Rural Hospital Improvement Grant Program $12,094
93.399 Cancer Control $11,675
93.083 Prevention of Disease, Disability, and Death Through Immunization and Control of Respiratory and Related Diseases $10,352
93.226 Research on Healthcare Costs, Quality and Outcomes $8,910
16.017 Sexual Assault Services Formula Program $8,657
93.624 Aca - State Innovation Models: Funding for Model Design and Model Testing Assistance $7,614
93.242 Mental Health Research Grants $7,286
93.069 Public Health Emergency Preparedness $6,078
16.813 Nics Act Record Improvement Program $6,000
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $5,480
16.320 Services for Trafficking Victims $5,173
21.019 Coronavirus Relief Fund $5,000
93.959 Block Grants for Prevention and Treatment of Substance Abuse $4,049
84.425 Education Stabilization Fund $3,773
93.837 Cardiovascular Diseases Research $1,500
93.788 Opioid Str $356
20.600 State and Community Highway Safety $69