Finding Text
Finding 2023-007 – N. Special Tests and Provisions – Borrower Data and Reconciliation
Information on Federal Program(s) - Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement - Each month, the COD provides institutions with a School Account Statement (“SAS”) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution’s financial records. Since up to three Direct Loan program years may be open at any given time, institutions may receive three SAS data files each month.
Condition – The University was not able to provide supporting documentation to evidence that certain monthly SAS data file reconciliations were performed.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with the Borrower Data and Reconciliation requirements.
Questioned Costs – None.
Context – For 1 of 2 SAS reconciliations tested, the University was unable to provide documentation showing that the reconciliation was completed.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-002.
Recommendation – We recommend the University enhance its procedures and internal controls to ensure that SAS data files are reconciled monthly.
Views of Responsible Officials – For one of two reconciliations tested we were unable to provide documentation that the reconciliation was done. The reconciliation was done, however, there was a server error in the system that caused Wheeling to lose some files. Two of the reconciliation files are missing due to this.
We have a Financial Aid Office policy that has been established to ensure that reconciliations are made once a month. Since the loss of the backup system, the files are both saved and printed to avoid any more loss of files.
During this period, we were using a now-defunct backup system. We have now moved to multiple backup systems and a new storage server. Our storage server is now a virtual machine with a high availability setup where we have 2 large drive systems continually being mirrored. The backup system has 2 servers with large drive systems. We continually alternate file backups each day as needed. As the backups finish, they are moved up to the cloud each time. Also, we have in place a 30-day non-overwrite policy on the files backed up to the cloud.