University of RichmondHigher Education

Finding 2020-001: Special Test and Provision - Disbursements to or on Behalf of Students Federal Award Year July 1, 2019 through June 30, 2020 Federal Program Student Financial Assistance; CFDA Number 84.268 ? Federal Direct Student Loan Program Federal Agency U.S. Department of Education Criteria: Per 34 CFR section 668.165(a)(3), if an institution credits a student?s account with a Direct Loan, the institution must notify the student or parent in writing of the date and amount of the disbursement, the student?s right or parent?s right to cancel all or a portion of that loan or loan disbursement, and have the loan proceeds returned to the holder of that loan, and the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or loan disbursement. Further, for institutions that implement affirmative confirmation, the loan disbursement notification must be made no earlier than 30 days before, and no later than 30 days after crediting the student?s account with the loan. Per 2 CFR 200.303, the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Found, Including Perspective We selected 40 students for testing of loan disbursements notification and noted that one student did not receive a notification of their Fall 2019 loan disbursements. The Spring 2020 disbursements notifications were sent within the requirement for the 40 students selected for testing. Possible Cause and effect Loan disbursement notifications are initiated by the Office of Financial Aid weekly. Due to the wrong date range used in the notification process, students with loan disbursements on certain days were not sent loan disbursement notifications. The Office of Financial Aid also did not monitor the notification process to ensure compliance. Questioned Costs None identified. Whether the sampling was a statistically valid sample The sample was not intended to be, and was not, a statistically valid sample.

Finding 2020-002: Enrollment Reporting Federal Award Year July 1, 2019 through June 30, 2020 Federal Program Student Financial Assistance; CFDA Number 84.268 ? Federal Direct Student Loan Program Federal Agency U.S. Department of Education Criteria Per 34 CFR Section 685.309 and 34 CFR Section 690.83, a school shall complete and return the student status confirmation report to the Secretary within 60 days of receipt. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Per 34 CFR Section 685.309 and 34 CFR Section 690.83, institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website for both Campus Level and Program Level enrollment information. Per 2 CFR 200.303, the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Found, Including Perspective In the program level enrollment data, there were 2 out of 40 students for which the program enrollment effective date did not agree to the University?s records. Possible Cause and Effect Management?s control over the review for accuracy of the information submitted for program level enrollment reporting was not operating consistently during the fiscal year. Questioned Costs None identified. Whether the sampling was a statistically valid sample The sample was not intended to be, and was not, a statistically valid sample.

Findings and Questioned Costs Relating to Federal Awards Finding 2019-001: Special Test and Provision - Disbursements to or on Behalf of Students Project Period July 1, 2018 through June 30, 2019 Federal Program Student Financial Assistance; CFDA Number 84.268 ? Federal Direct Student Loan Program Federal Agency Department of Education Criteria Per 34 CFR section 668.165(a)(3), if an institution credits a student?s account with a Direct Loan, the institution must notify the student or parent in writing of the date and amount of the disbursement, the student?s right or parent?s right to cancel all or a portion of that loan or loan disbursement, and have the loan proceeds returned to the holder of that loan, and the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or loan disbursement. Further, for institutions that implement affirmative confirmation, the loan disbursement notification must be made no earlier than 30 days before, and no later than 30 days after crediting the student?s account with the loan. Condition and context We selected 40 students for testing of loan disbursements notification, and noted that one student did not receive a notification of their Fall 2018 loan disbursements. Cause and effect Loan disbursement notifications are initiated by the Office of Financial Aid weekly. Due to the wrong date range used in the notification process, students with loan disbursements on certain days were not sent loan disbursement notifications. The Office of Financial Aid also did not monitor the notification process to ensure compliance. Questioned Costs None. Whether the sampling was a statistically valid sample The sample was not intended to be, and was not, a statistically valid sample. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit A similar finding was reported in the prior year?s audit as finding number 2018-001. Recommendation We recommend the University enhance its controls over the loan disbursements notification process to ensure that the proper parameters are used when initiating the notification process on a weekly basis. We also recommend an after-the-fact review of notifications to ensure compliance. Views of Responsible Officials Management concurs with KPMG?s recommendation to enhance its controls over the loan disbursements notification process as well as perform a review of notification to ensure compliance. As of January 15, 2020 these procedures have been updated and all impacted students through this date have been notified of their loan disbursement. Procedures for reviewing notifications have been implemented and are being closely monitored.

GSA_MIGRATION