Finding 1123687 (2024-001)

Significant Deficiency
Requirement
E
Questioned Costs
$1
Year
2024
Accepted
2025-03-31
Audit: 351580
Organization: Johnson C. Smith University (NC)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The University improperly calculated Pell awards and disbursed Direct Loans that did not match students' academic levels.
  • Impacted Requirements: Non-compliance with federal eligibility criteria for Title IV aid, risking improper disbursements and potential questioned costs.
  • Recommended Follow-Up: Enhance internal controls and implement formal policies to ensure accurate calculation and awarding of Title IV aid, alongside transitioning to a more robust financial aid management system.

Finding Text

Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Pell Grant Program (ALN: 84.063), and Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Federal Pell Grant (“Pell”) (Assistance Listing 84.063) – Each year, based on the maximum Pell Grant established by Congress, the Department of Education (“ED”) provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their expected family contribution (“EFC”) and cost of attendance (“COA”). The Disbursement Schedules are used to determine annual awards for full-time, three-quarter time, half-time, and less-than-half-time students. The steps to determine Pell awards are as follows: (a) Determine the student’s enrollment status, (b) calculate the cost of attendance, (c) determine the annual award, (d) determine the payment period, (e) calculate the payment for the payment periods, and (f) disburse funds at prescribed times. E. Eligibility – Federal Direct Student Loans (“Direct Loans”) (Assistance Listing 84.268) - Direct Subsidized Loans and Direct Unsubsidized Loans have annual loan limits that vary based on the student's grade level and (for Direct Unsubsidized Loans) dependency status (34 CFR 685.203). The annual loan limit is the maximum amount that a student may receive for an academic year. For undergraduate students there is a combined annual loan limit for Direct Subsidized Loans and Direct Unsubsidized Loans, of which not more than a specified amount may be comprised of Direct Subsidized Loans (“annual subsidized maximum”). For independent undergraduate students (and for dependent undergraduate students whose parents are unable to obtain Direct PLUS Loans), the annual loan limits are (34 CFR 685.203(a) and (c): • $9,500 for independent first-year undergraduates, not more than $3,500 of which may be subsidized; • $10,500 for independent second-year undergraduates, not more than $4,500 of which may be subsidized; and • $12,500 for independent third-, fourth-, and fifth-year undergraduates, not more than $5,500 of which may be subsidized. E. Eligibility – Campus-Based Programs (Federal Work-Study “FWS”, Federal Supplemental Educational Opportunity Grant “FSEOG”) (Assistance Listing 84.033, Assistance Listing 84.007) - The maximum amount that can be awarded under the campus-based programs is equal to the student’s financial need (COA minus EFC) minus aid from other SFA programs and other resources. Condition: For certain students tested, the University improperly calculated the student’s Pell award. Additionally, for certain students, the University awarded and disbursed Direct Loans in an amount that was not commensurate with the student’s academic level. Cause: Insufficient administrative oversight and internal controls with respect to Title IV award eligibility. Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly calculate eligible award amounts and properly award and disburse aid in accordance with the required guidelines could result in improper disbursements of Title IV aid. Questioned Costs: Known questioned costs: $2,995; total questioned costs: indeterminable. Context: We noted the following exceptions during our testing: • For 2 of 25 students selected for testing, the amount of Pell awarded and disbursed to the student exceeded the student’s eligible award. • For 1 of 25 students selected for testing, the University awarded and disbursed Direct Loans and FSEOG to the student in an amount that was not commensurate with the student’s academic level and/or need, resulting in an overaward of Direct Loans aid. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and implement formal policies and procedures over the applicable compliance requirements to ensure that Title IV aid is properly calculated, awarded, and disbursed consistent with federal regulations. Views of Responsible Officials: The University did not appropriately review eligibility documentation resulting in over awards. The error arose due to the manual processing of student loans by a single financial counselor without adequate checks, leading to non-compliance with specific fund restrictions related to the student’s year in school and dependency status. A significant contributing factor was the absence of structured, periodic quality assurance reviews. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. In addition, as part of the University’s transition of its ERP system from Jenzabar to Colleague, Financial Aid will transition from the use of PowerFaids to Ellucian Colleague for financial aid management, which was driven by the need for more robust, systematic controls that can accurately adjust and calculate Cost of Attendance (COA) on a per-student basis. This system change is expected to automate many of the processes that were previously prone to human error, ensuring compliance with regulatory requirements. The University’s Financial Aid counselors will continue to monitor students' credit hours and make necessary adjustments to aid awards, thereby maintaining compliance and addressing any discrepancies proactively. This plan reflects our commitment to upholding the highest standards of financial aid management and ensuring that our processes are transparent, compliant, and responsive to the needs of our students. The University will integrate automated processes in our financial aid packaging to reduce human error. The adoption of the Ellucian Colleague system by JCSU will allow for automatic enforcement of packaging and transmittal rules, tailored to specific funds. Additionally, we will utilize exception reports from Ellucian Colleague to identify and correct discrepancies in real-time. We will establish a routine monitoring system to regularly check the accuracy of financial aid awards against eligibility criteria.

Categories

Questioned Costs Student Financial Aid Subrecipient Monitoring Eligibility Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 547245 2024-001
    Significant Deficiency
  • 547246 2024-001
    Significant Deficiency
  • 547247 2024-001
    Significant Deficiency
  • 547248 2024-002
    Significant Deficiency
  • 547249 2024-002
    Significant Deficiency
  • 547250 2024-003
    Significant Deficiency
  • 547251 2024-003
    Significant Deficiency
  • 547252 2024-003
    Significant Deficiency
  • 547253 2024-003
    Significant Deficiency
  • 547254 2024-004
    Significant Deficiency
  • 547255 2024-005
    Significant Deficiency
  • 547256 2024-005
    Significant Deficiency
  • 547257 2024-005
    Significant Deficiency
  • 547258 2024-005
    Significant Deficiency
  • 547259 2024-006
    Significant Deficiency
  • 547260 2024-006
    Significant Deficiency
  • 547261 2024-007
    Significant Deficiency
  • 547262 2024-007
    Significant Deficiency
  • 547263 2024-007
    Significant Deficiency
  • 547264 2024-008
    Material Weakness Repeat
  • 547265 2024-008
    Material Weakness Repeat
  • 547266 2024-008
    Material Weakness Repeat
  • 547267 2024-008
    Material Weakness Repeat
  • 547268 2024-008
    Material Weakness Repeat
  • 547269 2024-008
    Material Weakness Repeat
  • 547270 2024-009
    Significant Deficiency Repeat
  • 547271 2024-009
    Significant Deficiency Repeat
  • 547272 2024-010
    Significant Deficiency Repeat
  • 547273 2024-010
    Significant Deficiency Repeat
  • 547274 2024-010
    Significant Deficiency Repeat
  • 547275 2024-011
    Material Weakness Repeat
  • 547276 2024-011
    Material Weakness Repeat
  • 547277 2024-012
    Significant Deficiency Repeat
  • 547278 2024-012
    Significant Deficiency Repeat
  • 1123688 2024-001
    Significant Deficiency
  • 1123689 2024-001
    Significant Deficiency
  • 1123690 2024-002
    Significant Deficiency
  • 1123691 2024-002
    Significant Deficiency
  • 1123692 2024-003
    Significant Deficiency
  • 1123693 2024-003
    Significant Deficiency
  • 1123694 2024-003
    Significant Deficiency
  • 1123695 2024-003
    Significant Deficiency
  • 1123696 2024-004
    Significant Deficiency
  • 1123697 2024-005
    Significant Deficiency
  • 1123698 2024-005
    Significant Deficiency
  • 1123699 2024-005
    Significant Deficiency
  • 1123700 2024-005
    Significant Deficiency
  • 1123701 2024-006
    Significant Deficiency
  • 1123702 2024-006
    Significant Deficiency
  • 1123703 2024-007
    Significant Deficiency
  • 1123704 2024-007
    Significant Deficiency
  • 1123705 2024-007
    Significant Deficiency
  • 1123706 2024-008
    Material Weakness Repeat
  • 1123707 2024-008
    Material Weakness Repeat
  • 1123708 2024-008
    Material Weakness Repeat
  • 1123709 2024-008
    Material Weakness Repeat
  • 1123710 2024-008
    Material Weakness Repeat
  • 1123711 2024-008
    Material Weakness Repeat
  • 1123712 2024-009
    Significant Deficiency Repeat
  • 1123713 2024-009
    Significant Deficiency Repeat
  • 1123714 2024-010
    Significant Deficiency Repeat
  • 1123715 2024-010
    Significant Deficiency Repeat
  • 1123716 2024-010
    Significant Deficiency Repeat
  • 1123717 2024-011
    Material Weakness Repeat
  • 1123718 2024-011
    Material Weakness Repeat
  • 1123719 2024-012
    Significant Deficiency Repeat
  • 1123720 2024-012
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $10.89M
84.063 Federal Pell Grant Program $4.74M
11.028 Connecting Minority Communities Pilot Program $2.35M
84.031 Higher Education Institutional Aid $555,668
84.007 Federal Supplemental Educational Opportunity Grants $480,658
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $446,604
84.042 Trio Student Support Services $441,950
84.120 Minority Science and Engineering Improvement $427,368
84.033 Federal Work-Study Program $390,521
93.317 Emerging Infections Programs $363,742
84.217 Trio McNair Post-Baccalaureate Achievement $322,726
84.047 Trio Upward Bound $256,358
47.076 Stem Education (formerly Education and Human Resources) $137,979
15.932 Preservation of Historic Structures on the Campuses of Historically Black Colleges and Universities (hbcus). $63,530
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $51,145
93.310 Trans-Nih Research Support $48,409
45.313 Laura Bush 21st Century Librarian Program $40,928
12.598 Centers for Academic Excellence $32,974
97.062 Scientific Leadership Awards $27,918
84.335 Child Care Access Means Parents in School $23,238
17.268 H-1b Job Training Grants $20,962
97.061 Centers for Homeland Security $17,900
11.417 Sea Grant Support $14,474
54.001 Intelligence Community Centers for Academic Excellence $11,094
89.003 National Historical Publications and Records Grants $6,956
84.425 Education Stabilization Fund $4,647
93.859 Biomedical Research and Research Training $1,550