Finding Text
Finding No. 2022-001 ? Enrollment Reporting and Documentation of Controls Significant Deficiency Federal Program: Student Financial Aid Cluster - Federal Direct Student Loans (ALN 84.268), U.S. Department of Education Criteria: Per 2 CFR 200.303, recipients of federal awards must establish and maintain effective internal control over federal awards to provide reasonable assurance that federal awards are managed in a way that is compliant with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We noted a lack of controls in the enrollment reporting compliance requirement and lack of documentation that demonstrates application of controls in cash management and direct loan reconciliation compliance requirements. Cause: High turnover and limited resources. Effect: Ineffective control procedures or lack thereof over material compliance requirements could result in compliance findings and questioned costs. Reportable questioned costs: None. Context: RSM tested enrollment reporting under the special test compliance requirement. In reviewing controls over reporting student status changes to the National Student Loan Data System, RSM identified that there is no independent review over the submission to ensure its accuracy and timely submission. RSM also identified that there was a lack of documentation to demonstrate the application of controls the Institute has in place over both the cash management compliance requirement and direct loan reconciliation compliance requirement that is part of the special tests. Repeat Finding: No Recommendation: We recommend the Institute establish control procedures around enrollment reporting compliance requirement that includes an independent review over the student status submission. We also recommend that the Institute ensure that all controls in place include documentation that demonstrates application of controls. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.