Finding 669357 (2022-003)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-03-30
Audit: 83936
Organization: Avila University (MO)
Auditor: Forvis LLP

AI Summary

  • Core Issue: The University failed to submit accurate Pell and Direct Loan records to the Common Origination and Disbursement (COD), leading to discrepancies in disbursement dates and award amounts.
  • Impacted Requirements: Compliance with 34 CFR 690.83 and related guidance requires timely and accurate reporting of financial aid data to the COD.
  • Recommended Follow-Up: The University should continue its new monthly reconciliation process to ensure data accuracy and submit records to the COD by the end of the next business day.

Finding Text

Student Financial Assistance Cluster U.S. Department of Education CFDA Nos. 84.268, 84.063, Federal Direct Student Loans - Award Year 2022 Federal Pell Grant Program - Award Year 2022 Criteria or Specific Requirement ? Reporting According to 34 CFR 690.83, Dear Colleague Letter Gen 13-13, and Federal Register Volume 84, Number 212, November 1, 2019, an institution must submit Pell and Direct Loan origination records and disbursement records to the Common Origination and Disbursement (COD) in a timely and accurate manner. Condition ? Federal Direct Loan and Pell disbursement dates per the University's billing system did not agree with the reportd dates per the Common Origination Disbursement (COD) records. Cost of attendance transaction numbers, and the Pell award amount did not agree between the students' file and COD records. Questioned Costs ? None noted. Context ? Out of a population of 931 students receiving Direct Loan awards and 541 students receiving Pell awards during the year, a sample of 40 students were selected for testing. Thirteen errors were noted. There were five instances in which the student's COA were not consistent with the COD for Pell awards. There were five instances in which the student's disbursement date was not consistent with the COD, and three instances in which the student's transaction code was not consistent with the COD for Direct Loan awards. The sample was not, and was not intended to be, a statistically valid sample. Effect ? The University did not report the accurate data (e.g., disbursement dates, amounts, and cost of attendance) to the COD. Cause ? Lack of reconciliation of student origination records to data provided to the COD. Identification as a Repeat Finding ? No Recommendation ? The University should review and update its processes and controls to ensure a formal reconciliation is provided for student origination records to the COD. Views of Responsible Officials and Planned Corrective Actions - Management has overhauled the underlying processes to include formal monthly reconciliations and additional levels of review. Further, the new process requires that Pell and Direct Loan origination and disbursement records are submitted to the COD by the end of next business day. The newly implemented reconciliation process validates disbursement dates, amounts and COA in the COD.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Other Findings in this Audit

  • 92912 2022-002
    Significant Deficiency Repeat
  • 92913 2022-003
    Significant Deficiency
  • 92914 2022-002
    Significant Deficiency Repeat
  • 92915 2022-003
    Significant Deficiency
  • 669354 2022-002
    Significant Deficiency Repeat
  • 669355 2022-003
    Significant Deficiency
  • 669356 2022-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $8.72M
84.063 Federal Pell Grant Program $2.68M
84.425 Covid-19 - Education Stabilization Fund/student Aid $2.04M
84.047 Trio_upward Bound $354,795
84.031 Higher Education_institutional Aid $351,631
84.047 Trio_project Achieve $339,859
84.042 Trio_student Support Services $294,790
84.425 Covid-19 - Education Stabilization Fund/strengthening Institutions Program Application $178,239
47.076 Education and Human Resources $111,861
84.033 Federal Work-Study Program $101,607
84.007 Federal Supplemental Educational Opportunity Grants $83,800
16.525 Grants to Reduce Domestic Violence, Dating Violence, Sexual Assault, and Stalking on Campus $11,871
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $11,256
93.925 Scholarships for Health Professions Students From Disadvantaged Backgrounds $4,845