Finding Text
Finding 2023-001 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiencies)
Information on the federal program – Federal Direct Student Loans, CFDA No. 84.268, June
30, 2023; Federal Work-Study Program, CFDA No. 84.033, June 30, 2023.
Criteria – Federal regulations governing Title IV programs.
Condition – Instances of noncompliance were noted as more fully described in the context below.
Questioned Costs – $54,230
Context – We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs:
a. Two (2) out of 21 students did not complete exit counseling requirements upon graduating or dropping below half-time status. 34 CFR 685.304(b)(1)
b. One (1) out of 21 students was awarded Federal Direct Loans at less than half-time status. 34 CFR 685.200 (a)(1)(i). Attributable questioned cost: $3,000
c. Documentation to support the Center’s reconciliation of the Federal Direct Loan program between Common Origination and Disbursement (COD) and the Office of Financial aid was not available. 34 CFR 685.300(b)(5)
d. Documentation to support the Center’s reconciliation of the Federal Work-study program was not available. 34 CFR Part 668 Subpart L
e. One (1) out of 21 students did not have timely or accurate enrollment reporting to the National Student Loan Data System (NSLDS). 34 CFR685.309(b)
f. Documentation to conduct Federal Work Study compliance testing was not provided. 34 CFR Part 675
g. Documentation to support testing for withdrawals and the return of Title IV funds compliance was not provided. HEA Section 484B & 34 CFR 668.22
h. Documentation to support credit balance (student refund) testing was not provided. 34 CFR 668.164(h)(1)
i. Two (2) students out of 21 students were paid federal Direct Loans and did not make satisfactory academic progress (SAP) for the academic year. Additionally, the school did not provide updated documents supporting successful appeals. 34 CFR 668.34. Attributable questioned cost: $30,730
j. One (1) out of 21 students did not have an undergraduate transcript to prove eligibility for the program they were enrolled within the institution. HEA Section 484(d) and 34 CFR 668.32. Attributable questioned cost: $20,500.
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The Center’s participation in the Title IV programs could be subject to USDE sanctions as applicable.
Auditor's Recommendation – The Center should implement corrective actions to ensure that the above findings are resolved and does not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of compliance steps, technical training of staff, and adequate procedures are being followed for compliance purposes.