FINDING 2024-001
Finding Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Verification
Summary of Finding:
The University had designed a key control that one employee would perform the required
verifications, and a second employee would then review a sample of those ver...
FINDING 2024-001
Finding Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Verification
Summary of Finding:
The University had designed a key control that one employee would perform the required
verifications, and a second employee would then review a sample of those verifications. However,
the control was not properly implemented or operating effectively as the University had not
established proper segregation of duties. The same employee was responsible for performing and
reviewing verifications during the audit period without an independent oversight, review, or approval
process involving a second employee.
Contact Person Responsible for Corrective Action: Joanna Riney, Director of Student Financial
Assistance
Contact Phone Number and Email Address: 812-465-7049; jriney@usi.edu
Views of Responsible Officials:
We concur with the finding.
While the University of Southern Indiana had internal controls in place to prevent aid from disbursing
before verification was marked complete and assigned responsibility for verification processing to a
well-trained employee with 20 years of verification processing experience, staff vacancies in the
department in addition to training and preparation for vast changes in application, award calculation,
and system controls for the 2024-2025 aid year limited the ability to conduct an independent review
on a sample of students for which verification had been performed. Given the fact that there were
very minimal changes to the verification process from the verification process performed in the last
several years, in lieu of an independent review, management determined that for the 2023-2024 aid
year, utilizing an after-the-fact review on a sample of completed verifications by the employee
performing the verification, to review/double-check the verification procedures, provided reasonable
assurance that compliance would be achieved. No instances of non-compliance in verification
procedures were detected in the audit.
Description of Corrective Action Plan:
Staffing levels are returning to normal and new staff have a more complete understanding of overall
financial aid including the verification process. Also, the Department of Education has provided
additional clarification and guidance for all 2024-2025 processing and reduced the number of
students selected for verification, allowing management the ability to resume the performance of an
independent review on a sample of students for which verification had been performed.
Anticipated Completion Date:
The independent review was reinstated effective for verifications performed in Fall 2024 and going
forward.Per Uniform Guidance:
2 CFR § 200.511(a) – “The auditee is responsible for follow-up and corrective action on all audit findings. . .The auditee must also
prepare a corrective action plan for current year audit findings. . .The corrective action plan and summary schedule of prior audit findings
must include findings relating to the financial statements which are required to be reported in accordance with GAGAS. ”
2 CFR § 200.511(c) – “At the completion of the audit, the auditee must prepare, in a document separate from the auditor's findings
described in § 200.516, a corrective action plan to address each audit finding included in the current year auditor's reports. The corrective
action plan must provide the name(s) of the contact person(s) responsible for corrective action, the corrective action planned, and the
anticipated completion date. If the auditee does not agree with the audit findings or believes corrective action is not required, then the
corrective action plan must include an explanation and specific reasons.”