Information on Federal Program ‒ Federal Family Education Loans (Assistance Listing Number 84.032)
Criteria – Compliance Requirement C – Cash Management – The University must return all excess cash
received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled
student’s account within 3 business days following the receipt of funds.
Condition – During the audit, we noted the following:
The University has approximately $388,000 of excess cash held in a segregated federal funds cash
account, which relates to awards from prior years.
Cause – Prior management’s lack of oversight of student financial aid in prior years. The lack of proper
oversight and insufficient internal controls resulted in excess cash received from third-party awarding
agencies, which was not properly refunded, causing the University to have excess cash on hand.
Effect – The University has excess cash on hand and was not in compliance with cash management
requirements; however, the University has the funds properly held in an identifiable federal funds cash
account, as they are currently investigating the best way to refund the excess cash.
Questioned Costs – None.
Context – We reviewed cash received and expended in a prior year, noting the University has additional
funds on hand from prior awarding years. All current year funds were properly received and disbursed with
no excess cash on hand from the current year. The University reconciled the remaining amounts and
discovered the transactions the excess cash relates to. The University is working with the Government to
send the funds back however at year end they have not been returned.
Indication of a Repeat Finding – This is a repeat finding 2023-003 from prior year.
Recommendation – We recommend the University enhance internal controls over compliance with cash
management requirements, as well as work with current and prior awarding agencies to determine the
appropriate course of action to return the excess cash on hand.
Views of Responsible Officials – The cash balance of federal financial aid funds does not pertain to the
currently audited year. The University is diligently ensuring that these funds continue to remain separate
while undergoing reconciliation and has safeguarded them from expenditure. Given the complexity of
reviewing each student’s history, we’ve enlisted the expertise of an external financial aid consulting firm
experienced in reconciling FFEL loan programs.
Information on Federal Program ‒ Federal Work-Study Program (Assistance Listing Number 84.033)
Criteria – Compliance Requirement N – Special Tests and Provisions – Institutions are required to verify
students are not earning Federal Work-Study program financial aid during scheduled class time, and all
amounts paid are appropriately earned.
Condition – During our testing of the Federal Work-Study program, we noted the following:
For 3 students out of 10 sampled, from a population of 298 students who received Federal Work-
Study, the University was unable to provide proper documentation to verify the student was not
earning Federal Work-Study Financial Aid during scheduled class time.
For 2 students out of a population of 298 students who received Federal Work-Study, the University
was unable to verify time punches, which resulted in overpayments of Federal Work-Study aid;
however, the University was able to prove no refund was needed as there were offsetting hours
that were subsequently claimed as allowable hours.
Cause – Insufficient documentation related to internal controls in the Federal Work-Study program,
resulting in 3 students appearing to work during scheduled class time without proper documentation on file,
and 2 students whose time entered and paid were not able to be verified.
Effect – The students and the University were not in compliance with the Federal Work-Study program
guidelines.
Questioned Costs – $1,533
Context – As noted in the condition, 5 total exceptions were found, which resulted in the students and the
University not being in compliance with the program rules.
Indication of a Repeat Finding – This is a repeat finding 2023-004 from prior year.
Recommendation – We recommend the University ensure its internal controls, policies and procedures
are followed on a consistent basis regarding the Federal Work-Study Program.
Views of Responsible Officials – The University consistently emphasizes to both its students and student
supervisors that students should not work during their scheduled class times, regardless of whether the
class is cancelled or ends early. This expectation is reiterated during training sessions for supervisors and
through publications distributed to them.
Information on Federal Program ‒ Federal Family Education Loans (Assistance Listing Number 84.032)
Criteria – Compliance Requirement C – Cash Management – The University must return all excess cash
received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled
student’s account within 3 business days following the receipt of funds.
Condition – During the audit, we noted the following:
The University has approximately $388,000 of excess cash held in a segregated federal funds cash
account, which relates to awards from prior years.
Cause – Prior management’s lack of oversight of student financial aid in prior years. The lack of proper
oversight and insufficient internal controls resulted in excess cash received from third-party awarding
agencies, which was not properly refunded, causing the University to have excess cash on hand.
Effect – The University has excess cash on hand and was not in compliance with cash management
requirements; however, the University has the funds properly held in an identifiable federal funds cash
account, as they are currently investigating the best way to refund the excess cash.
Questioned Costs – None.
Context – We reviewed cash received and expended in a prior year, noting the University has additional
funds on hand from prior awarding years. All current year funds were properly received and disbursed with
no excess cash on hand from the current year. The University reconciled the remaining amounts and
discovered the transactions the excess cash relates to. The University is working with the Government to
send the funds back however at year end they have not been returned.
Indication of a Repeat Finding – This is a repeat finding 2023-003 from prior year.
Recommendation – We recommend the University enhance internal controls over compliance with cash
management requirements, as well as work with current and prior awarding agencies to determine the
appropriate course of action to return the excess cash on hand.
Views of Responsible Officials – The cash balance of federal financial aid funds does not pertain to the
currently audited year. The University is diligently ensuring that these funds continue to remain separate
while undergoing reconciliation and has safeguarded them from expenditure. Given the complexity of
reviewing each student’s history, we’ve enlisted the expertise of an external financial aid consulting firm
experienced in reconciling FFEL loan programs.
Information on Federal Program ‒ Federal Work-Study Program (Assistance Listing Number 84.033)
Criteria – Compliance Requirement N – Special Tests and Provisions – Institutions are required to verify
students are not earning Federal Work-Study program financial aid during scheduled class time, and all
amounts paid are appropriately earned.
Condition – During our testing of the Federal Work-Study program, we noted the following:
For 3 students out of 10 sampled, from a population of 298 students who received Federal Work-
Study, the University was unable to provide proper documentation to verify the student was not
earning Federal Work-Study Financial Aid during scheduled class time.
For 2 students out of a population of 298 students who received Federal Work-Study, the University
was unable to verify time punches, which resulted in overpayments of Federal Work-Study aid;
however, the University was able to prove no refund was needed as there were offsetting hours
that were subsequently claimed as allowable hours.
Cause – Insufficient documentation related to internal controls in the Federal Work-Study program,
resulting in 3 students appearing to work during scheduled class time without proper documentation on file,
and 2 students whose time entered and paid were not able to be verified.
Effect – The students and the University were not in compliance with the Federal Work-Study program
guidelines.
Questioned Costs – $1,533
Context – As noted in the condition, 5 total exceptions were found, which resulted in the students and the
University not being in compliance with the program rules.
Indication of a Repeat Finding – This is a repeat finding 2023-004 from prior year.
Recommendation – We recommend the University ensure its internal controls, policies and procedures
are followed on a consistent basis regarding the Federal Work-Study Program.
Views of Responsible Officials – The University consistently emphasizes to both its students and student
supervisors that students should not work during their scheduled class times, regardless of whether the
class is cancelled or ends early. This expectation is reiterated during training sessions for supervisors and
through publications distributed to them.