Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or Specific Requirement: Per 2 CFR section 200.303(a), a 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. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller
General of the United States or the “Internal Control Integrated Framework,” issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: During the audit, it was observed that the University did not have adequate segregation of
duties in its financial aid office and did not maintain supporting documentation. The Director of Financial
Aid prepares is responsible for authorizing, processing, and reviewing transactions related to Title IV
funds.
Questioned Costs: N/A
Context: Effective internal controls are crucial to ensure funds are properly managed and disbursed.
There are instances where the Director of Financial Aid is reviewing and approving financial aid
packages, reconciliations and other required reports. We also noted instances were supporting
documentation could not be provided.
Cause: The University’s financial aid processes have overlapping responsibilities which has resulted in
inadequate segregation of duties.
Effect: The absence of proper segregation of duties increases risk for errors, noncompliance, and
inaccuracies in awarding and reporting of Title IV funds.
Repeat Finding: No
Recommendation: We recommend the University implement additional internal controls to ensure
proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to
separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing
training should be provided to financial aid staff on the importance of internal controls and compliance
with Title IV regulations.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.