Finding 949118 (2023-005)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-03-06
Audit: 293797
Organization: Berklee College of Music, Inc. (MA)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: The College's Financial Aid Operations did not update the Common Origination and Disbursement (COD) system with accurate enrollment dates and cost of attendance, leading to discrepancies in records.
  • Impacted Requirements: This situation violates federal regulations requiring effective internal controls to ensure accurate reporting and compliance with federal award terms.
  • Recommended Follow-Up: The College should enhance its processes for reporting to the COD system, ensuring that all key information is updated promptly to align with internal records.

Finding Text

Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. The disbursement record reports the actual disbursement date, amount of the disbursement, enrollment dates, and the cost of attendance. ED processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition In testing the origination and disbursement data, key items to test on origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code, transaction number, cost of attendance, and academic calendar. During our testwork over the key items on origination records as reported on COD, KPMG identified the following: • 15 of the 40 students selected for testwork had cost of attendance amounts that did not agree to the College’s records. • 6 of the 40 students selected for testwork had academic start or end dates that did not agree to the College’s records. None of the items that were exceptions described above resulted in changes to the amounts awarded or disbursed to students by the College for the current fiscal year. Cause The condition resulted from the College Student Financial Aid Operations Department not reporting updated information to the COD System when changes were made to enrollment dates or the cost of attendance of the students identified due to the College not having an adequate internal control process. Possible Asserted Effect Failure to provide required key item information in accordance with federal requirements and implement sufficient internal controls to ensure the programs are operating effectively could have resulted in the College awarding or disbursing incorrect amounts to students. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding This is not a repeat finding. Recommendation We recommend the College review and enhance its process related to reporting key items to the COD System and update key fields as information may change during the awarding process to ensure that they agree to the College’s records.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Reporting

Other Findings in this Audit

  • 372674 2023-003
    Significant Deficiency
  • 372675 2023-004
    Significant Deficiency
  • 372676 2023-005
    Significant Deficiency
  • 372677 2023-006
    Significant Deficiency
  • 949116 2023-003
    Significant Deficiency
  • 949117 2023-004
    Significant Deficiency
  • 949119 2023-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $48.14M
84.063 Federal Pell Grant Program $5.92M
84.425 Education Stabilization Fund $2.08M
84.038 Federal Perkins Student Loans $1.88M
84.007 Federal Supplemental Educational Opportunity Grants $1.32M
84.033 Federal Work-Study Program $435,709
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $389,852