Finding 1161409 (2024-006)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-10-24
Audit: 371273
Organization: Wittenberg University (OH)
Auditor: RSM US LLP

AI Summary

  • Core Issue: The University reported inaccurate student data to the Common Origination and Disbursement (COD) system, affecting 4 out of 36 records reviewed.
  • Impacted Requirements: Noncompliance with 34 CFR 685.301(a)(8) and 34 CFR 685.309(b) regarding accurate reporting of student eligibility and loan information.
  • Recommended Follow-Up: Implement a quality assurance process with stronger controls to ensure accurate reporting and compliance moving forward.

Finding Text

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 and 84.268 Federal Agency: Various Award Year: 2024 Criteria: According to 34 CFR 685.301(a)(8), institutions must certify that the information provided to the Secretary is accurate and supported by institutional records. Additionally, 34 CFR 685.309(b) requires institutions to report to the Secretary accurate and complete information necessary for the administration of the Direct Loan Program, including student eligibility, loan amounts, and disbursement data. Condition: During the review of Direct Loan records, it was noted that 4 out of 36 students tested had discrepancies between the underlying support for Cost of Attendance (COA) and/or grade level and the information reported in the Common Origination and Disbursement (COD) system. Cause: The University did not have adequate internal controls or monitoring procedures in place to accurately report student data. Context: Controls did operate properly for the University to properly report student data to COD. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to properly report student data. Questioned Costs: None Repeat Finding: No Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

The discrepancies identified were the result of inconsistencies between internal student records and data transmitted to COD for Direct Loan origination. These errors occurred due to manual data entry and timing differences between updates made in the institution’s student information system (SIS) and those reflected in COD. Financial Aid staff received refresher training on Direct Loan data accuracy, COD reporting requirements, and verification procedures to ensure consistent documentation and communication between systems. Collaboration with IT Office is underway to establish automated data checks between the SIS and COD files to minimize the risk of future mismatches. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

Categories

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

Other Findings in this Audit

  • 1161387 2024-004
    Material Weakness Repeat
  • 1161388 2024-005
    Material Weakness Repeat
  • 1161389 2024-006
    Material Weakness Repeat
  • 1161390 2024-007
    Material Weakness Repeat
  • 1161391 2024-008
    Material Weakness Repeat
  • 1161392 2024-009
    Material Weakness Repeat
  • 1161393 2024-011
    Material Weakness Repeat
  • 1161394 2024-004
    Material Weakness Repeat
  • 1161395 2024-008
    Material Weakness Repeat
  • 1161396 2024-011
    Material Weakness Repeat
  • 1161397 2024-004
    Material Weakness Repeat
  • 1161398 2024-008
    Material Weakness Repeat
  • 1161399 2024-011
    Material Weakness Repeat
  • 1161400 2024-010
    Material Weakness Repeat
  • 1161401 2024-004
    Material Weakness Repeat
  • 1161402 2024-008
    Material Weakness Repeat
  • 1161403 2024-011
    Material Weakness Repeat
  • 1161404 2024-004
    Material Weakness Repeat
  • 1161405 2024-008
    Material Weakness Repeat
  • 1161406 2024-011
    Material Weakness Repeat
  • 1161407 2024-004
    Material Weakness Repeat
  • 1161408 2024-005
    Material Weakness Repeat
  • 1161410 2024-008
    Material Weakness Repeat
  • 1161411 2024-009
    Material Weakness Repeat
  • 1161412 2024-011
    Material Weakness Repeat
  • 1161413 2024-002
    Material Weakness Repeat
  • 1161414 2024-003
    Material Weakness Repeat
  • 1161415 2024-011
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $8.07M
84.063 FEDERAL PELL GRANT PROGRAM $2.45M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $1.72M
84.047 TRIO UPWARD BOUND $428,272
84.033 FEDERAL WORK-STUDY PROGRAM $257,699
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $168,199
84.021 OVERSEAS PROGRAMS - GROUP PROJECTS ABROAD $104,391
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $84,387
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $73,919
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $18,680
43.001 SCIENCE $8,473
45.162 PROMOTION OF THE HUMANITIES TEACHING AND LEARNING RESOURCES AND CURRICULUM DEVELOPMENT $7,260
81.049 OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM $2,386