Finding 1164671 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
$1
Year
2025
Accepted
2025-12-12
Audit: 374299
Organization: Union College (NE)

AI Summary

  • Core Issue: The University failed to disburse the full amounts of federal financial aid awarded to students, leading to underdisbursement.
  • Impacted Requirements: This finding violates federal regulations regarding accurate disbursement of Title IV aid, including Pell Grants and Stafford Loans.
  • Recommended Follow-Up: Enhance system controls to ensure that disbursements align with awarded amounts to achieve compliance.

Finding Text

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid FALN Number: Student Financial Aid Cluster Award Period: June 01, 2024 through May 31, 2025 Type of Finding: • Material Weakness in Internal Control Over Compliance • Other Matters Criteria or specific requirement: Federal regulations require institutions to award and disburse Title IV aid accurately and in accordance with student eligibility: Pell Grant: 34 CFR § 690.75 – Payment determination based on enrollment status and cost of attendance. FSEOG: 34 CFR § 676.10 – Must be awarded to students with exceptional financial need. Subsidized and Unsubsidized Stafford Loans: 34 CFR § 685.301 – Loan amounts must be based on grade level, dependency status, and cost of attendance. General Disbursement Requirements: 34 CFR § 668.164 – Institutions must disburse funds for the correct amount and payment period. Condition: A review of student financial aid records revealed that although students were accurately awarded federal financial aid—including Pell Grants, FSEOG, Subsidized Stafford Loans, and Unsubsidized Stafford Loans—based on documented eligibility and financial need, the actual disbursements were less than the awarded amounts. In several cases, students did not receive the full aid they were eligible for during the designated payment period, resulting in underdisbursement of funds. Questioned costs: $49,565 Context: During our testing, it was noted that 4 of 40 students were underdisbursed Pell, 12 of 40 students were underdisbursed SEOG, 7 of 40 students were underdisbursed Subsidized Stafford Loans, and 5 of 40 students were underdisbursed Unsubsidized Stafford Loans. Cause: The University did not have a process in place to ensure the student were disbursed in accordance with their federal awards. Effect: The University was not in compliance with Title IV aid regulations. Repeat finding: No Recommendation: We recommend the University enhance system controls to ensure disbursements match awards. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University enhance system controls to ensure disbursements match awards. View of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office normally attempts to disburse aid within the term for which it is designated. However, unusual workloads brought about by FAFSA disruptions, staffing reductions, and duty changes led to delays in the disbursement of some aid for the 2024-2025 school year. A significant amount of Fall 2024 and Spring 2025 aid was not disbursed until August and September 2025. While this does not fall outside of rules set by the Department of Education, later disbursements caused extra challenges for the Accounting Team and meant a delay in receiving federal funds into the organization. As of September 30, 2025, All Pell Grant and Federal Supplemental Education Opportunity Grant Funds for 2024-2025 were been dispersed — and the matching amounts have been certified by the Department of Education. All federal loans for 2024-2025 have been dispersed, with the exception of 11 students. Nine of the students still have not accepted or declined their loans. They have been given until October 15, or the loans will be rescinded. Two more students had errors that stopped disbursement. This issue is being resolved by the team within the next week. Actions taken to resolve the issue: The Financial Aid team is taking the following actions to ensure that financial aid is disbursed in the term it is awarded. (Note: there are always a few exceptions due to highly unusual circumstances.) • Restructuring the awarding process to disperse funds soon after Census Date, before manually checking each record for anomalies. In 2024-2025, the manual checking process was completed first, which dramatically delayed disbursement. • Restructuring duties to spread out the awarding processing among more than one team member to allow for it to be completed more quickly. • Reviewing and enhancing financial aid policies governing the awarding and disbursing process to ensure that the amounts match at the end of the fiscal year (May 31) for spring and fall terms, and at the end of the award year (August 1) for the summer term. Name(s) of the contact person(s) responsible for corrective action: Tricia Harris, Financial Aid Director Planned completion date for corrective action plan: The Financial Aid Office has already begun implementation of this action plan and will complete implementation before the end of the current school term.

Categories

Questioned Costs Student Financial Aid Eligibility Material Weakness

Other Findings in this Audit

  • 1164657 2025-001
    Material Weakness Repeat
  • 1164658 2025-001
    Material Weakness Repeat
  • 1164659 2025-001
    Material Weakness Repeat
  • 1164660 2025-001
    Material Weakness Repeat
  • 1164661 2025-001
    Material Weakness Repeat
  • 1164662 2025-002
    Material Weakness Repeat
  • 1164663 2025-002
    Material Weakness Repeat
  • 1164664 2025-002
    Material Weakness Repeat
  • 1164665 2025-002
    Material Weakness Repeat
  • 1164666 2025-002
    Material Weakness Repeat
  • 1164667 2025-003
    Material Weakness Repeat
  • 1164668 2025-003
    Material Weakness Repeat
  • 1164669 2025-003
    Material Weakness Repeat
  • 1164670 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $5.72M
84.063 FEDERAL PELL GRANT PROGRAM $1.44M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $280,298
84.031 HIGHER EDUCATION INSTITUTIONAL AID $214,413
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $172,190
84.033 FEDERAL WORK-STUDY PROGRAM $107,684