Finding 90881 (2022-004)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-27
Audit: 79889
Organization: Presentation College (SD)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: Presentation College failed to complete 9 out of 12 required monthly reconciliations of the School Account Statement (SAS), leading to discrepancies in reported data.
  • Impacted Requirements: Compliance with 34 CFR sections 685.301 and 685.303 regarding the origination and processing of federal direct loans was not met.
  • Recommended Follow-Up: Revise controls to ensure monthly reconciliations are performed and establish an independent review process for oversight.

Finding Text

2022-004 Department of Education Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans 2021-2022 Award Year Special Tests and Provisions ? Borrower Data Transmission and Reconciliation (Direct Loan) Significant Deficiency in Internal Controls over Compliance Criteria: 34 CFR sections 685.301 and 685.303 provide the criteria and guidance for origination and processing of direct loans. Presentation College is required to reconcile the monthly School Account Statement (SAS) data file to the institution?s financial records. Condition: When testing special tests and provisions related to COD, we noted the following: ?9 of the 12 monthly SAS reconciliations were not completed by Presentation College. ?1 of 60 students was incorrectly reported to COD as having received Title IV funds. Cause: Lack of oversight over the monthly reconciliation control resulted in 9 months of reconciliations that were not performed by Presentation College and variances/discrepancies that were not investigated. For the 1 student error, a batch process pushed the loan disbursement to COD, but the student did not receive the loan disbursement in the student account, so funds were never disbursed to student. Effect: The lack of monthly reconciliations of SAS data files can result in discrepancies not being found in a timely manner between amounts reported in COD compared to the institution?s records. Lack of reconciliations did result in an error of a student not receiving a loan that was reported to COD. Questioned Costs: None reported. Context/Sampling: All 12 monthly reconciliations were selected for testing to ascertain that a reconciliation is being performed on a monthly basis. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend that controls be revised to ensure that a monthly reconciliation of the SAS data file is being performed on a monthly basis going forward and a review process be in place to ensure the reconciliations are completed by someone outside of the person preparing the reconciliation. Views of Responsible Officials: Management agrees with the finding.

Corrective Action Plan

Finding 2022-004 Special Tests and Provisions ? Borrower Data Transmission and Reconciliation (Direct Loan) Significant Deficiency in Internal Controls over Compliance Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans Finding Summary: When testing special tests and provisions related to COD, the following was noted: ? 9 of the 12 monthly SAS reconciliations were not completed by Presentation College. ? 1 of 60 students was incorrectly reported to COD as having received Title IV funds. Responsible Individuals: James (Rocky) Query, Interim CFO and Jessica Papa, Director of Financial Aid Corrective Action Plan: Management has identified an outside consultant with the appropriate expertise to review current monthly SAS reconciliation processes. Anticipated Completion Date: We anticipate this external review to be completed over the next several weeks with implementation of recommended changes made prior to the end of the Spring term.

Categories

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions Matching / Level of Effort / Earmarking Significant Deficiency

Other Findings in this Audit

  • 88179 2022-003
    Significant Deficiency Repeat
  • 88180 2022-006
    Significant Deficiency Repeat
  • 88181 2022-007
    Significant Deficiency
  • 90879 2022-002
    Material Weakness Repeat
  • 90880 2022-003
    Significant Deficiency Repeat
  • 90882 2022-005
    Significant Deficiency
  • 90883 2022-006
    Significant Deficiency Repeat
  • 90884 2022-007
    Significant Deficiency
  • 90885 2022-006
    Significant Deficiency Repeat
  • 90886 2022-007
    Significant Deficiency
  • 90887 2022-002
    Material Weakness Repeat
  • 90888 2022-003
    Significant Deficiency Repeat
  • 90889 2022-005
    Significant Deficiency
  • 90890 2022-006
    Significant Deficiency Repeat
  • 90891 2022-007
    Significant Deficiency
  • 90892 2022-008
    Significant Deficiency
  • 90893 2022-010
    Significant Deficiency
  • 90894 2022-009
    Significant Deficiency
  • 90895 2022-010
    Significant Deficiency
  • 90896 2022-002
    Material Weakness Repeat
  • 664621 2022-003
    Significant Deficiency Repeat
  • 664622 2022-006
    Significant Deficiency Repeat
  • 664623 2022-007
    Significant Deficiency
  • 667321 2022-002
    Material Weakness Repeat
  • 667322 2022-003
    Significant Deficiency Repeat
  • 667323 2022-004
    Significant Deficiency Repeat
  • 667324 2022-005
    Significant Deficiency
  • 667325 2022-006
    Significant Deficiency Repeat
  • 667326 2022-007
    Significant Deficiency
  • 667327 2022-006
    Significant Deficiency Repeat
  • 667328 2022-007
    Significant Deficiency
  • 667329 2022-002
    Material Weakness Repeat
  • 667330 2022-003
    Significant Deficiency Repeat
  • 667331 2022-005
    Significant Deficiency
  • 667332 2022-006
    Significant Deficiency Repeat
  • 667333 2022-007
    Significant Deficiency
  • 667334 2022-008
    Significant Deficiency
  • 667335 2022-010
    Significant Deficiency
  • 667336 2022-009
    Significant Deficiency
  • 667337 2022-010
    Significant Deficiency
  • 667338 2022-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $3.85M
84.063 Federal Pell Grant Program $1.04M
84.425 Covid - 19, Education Stabilization Fund $579,418
84.038 Federal Perkins Loan Program $380,225
84.425 Covid -19 - Education Stabilization Fund $85,050
84.007 Federal Supplemental Educational Opportunity Grants $63,316
84.033 Federal Work-Study Program $45,246
21.019 Covid - 19 Coronavirus Relief Fund $32,978