Finding 623953 (2022-003)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-06
Audit: 41971
Organization: Culver-Stockton College (MO)
Auditor: Wade Stables PC

AI Summary

  • Core Issue: The College disbursed Title IV funds early to 14 first-time borrowers, violating the 30-day delay rule due to a misunderstanding of exemption criteria.
  • Impacted Requirements: Non-compliance with 34 CFR 668.164(i)(2) and 34 CFR 685.303(b)(5), risking program eligibility.
  • Recommended Follow-up: Provide training for staff on Title IV disbursement rules and implement monitoring procedures to ensure compliance with disbursement timelines.

Finding Text

Finding 2022-003 ? Early Disbursement of Title IV Funds (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: In accordance with 34 CFR 668.164(i)(2), Culver Stockton College may not make an early disbursement of a Direct Loan to a first-year, first-time borrower who is subject to the 30-day delayed disbursement requirements in 34 CFR 685.303(b)(5) unless the College is exempt from the 30-day delayed disbursement requirements under 34 CFR 685.303(b)(5)(i)(A). This exemption only applies to schools with a cohort default rate of less than 15 percent for each of the three most recent fiscal years for which data is available. Condition: In our sample of 60 students, the College disbursed Title IV funds to fourteen first-year, first-time borrowing students before the 30-day period expired. However, the College did not meet the exemption to the delayed disbursement requirement because its cohort default rate was more than 15 percent for one of the three most recent fiscal years available. Cause of Condition: The College typically falls under the exemption and is allowed early disbursement. They were aware of the year in which the cohort default rate was above 15 percent and properly followed the rules to delay disbursement until 30- days. However, they were not aware that the exemption takes into consideration each of the three most recent fiscal years available. Effect: Any deviations from Student Financial Assistance requirements may potentially jeopardize the College?s program eligibility. Questioned Costs: None. Perspective Information: Because the College was not aware that they did not meet the exemption, this is considered a systemic problem. Recommendation: We recommend the College provide additional training for staff involved in the disbursement of Title IV funds and ensure that the Official Cohort Default Rate notification is carefully reviewed and provided to all relevant personnel to ensure compliance with all changes mentioned in the notification. Also, implementing additional monitoring procedures to ensure disbursements are performed within the correct time periods allowed would help strengthen adherence to the requirements.

Categories

Student Financial Aid Subrecipient Monitoring Special Tests & Provisions Matching / Level of Effort / Earmarking Eligibility

Other Findings in this Audit

  • 47502 2022-002
    Significant Deficiency Repeat
  • 47503 2022-003
    Significant Deficiency
  • 47504 2022-004
    Significant Deficiency
  • 47505 2022-005
    Significant Deficiency
  • 47506 2022-002
    Significant Deficiency Repeat
  • 47507 2022-003
    Significant Deficiency
  • 47508 2022-004
    Significant Deficiency
  • 47509 2022-005
    Significant Deficiency
  • 47510 2022-002
    Significant Deficiency Repeat
  • 47511 2022-003
    Significant Deficiency
  • 47512 2022-004
    Significant Deficiency
  • 47513 2022-005
    Significant Deficiency
  • 47514 2022-002
    Significant Deficiency Repeat
  • 47515 2022-003
    Significant Deficiency
  • 47516 2022-004
    Significant Deficiency
  • 47517 2022-005
    Significant Deficiency
  • 47518 2022-002
    Significant Deficiency Repeat
  • 47519 2022-003
    Significant Deficiency
  • 47520 2022-004
    Significant Deficiency
  • 47521 2022-005
    Significant Deficiency
  • 623944 2022-002
    Significant Deficiency Repeat
  • 623945 2022-003
    Significant Deficiency
  • 623946 2022-004
    Significant Deficiency
  • 623947 2022-005
    Significant Deficiency
  • 623948 2022-002
    Significant Deficiency Repeat
  • 623949 2022-003
    Significant Deficiency
  • 623950 2022-004
    Significant Deficiency
  • 623951 2022-005
    Significant Deficiency
  • 623952 2022-002
    Significant Deficiency Repeat
  • 623954 2022-004
    Significant Deficiency
  • 623955 2022-005
    Significant Deficiency
  • 623956 2022-002
    Significant Deficiency Repeat
  • 623957 2022-003
    Significant Deficiency
  • 623958 2022-004
    Significant Deficiency
  • 623959 2022-005
    Significant Deficiency
  • 623960 2022-002
    Significant Deficiency Repeat
  • 623961 2022-003
    Significant Deficiency
  • 623962 2022-004
    Significant Deficiency
  • 623963 2022-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $6.68M
84.063 Federal Pell Grant Program $1.61M
84.007 Federal Supplemental Educational Opportunity Grants $91,746
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $66,010
84.033 Federal Work-Study Program $61,698
84.425 Education Stabilization Fund $20,000