FAC Explorer

Finding 1166270 (2025-002)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2025
Accepted
2025-12-23
Audit: 377340
Organization: Western Wyoming Community College (WY)
Auditor: MHP ASSURANCE SERVICES LLP

AI Summary

  • Core Issue: The Student Financial Aid Program failed to provide documentation for required monthly Direct Loan reconciliations.
  • Impacted Requirements: Non-compliance with 34 CFR 685.300(b)(5) may lead to additional conditions or remedies from the Federal awarding agency.
  • Recommended Follow-up: Implement a process for monthly reconciliations and ensure documentation is retained to avoid repeat findings.

Finding Text

Criteria: Per 34 CFR 685.300(b)(5), to participate in the Direct Loan Program, a school must, on a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to, and accepted by, the Secretary. Condition/context: The Student Financial Aid Program was unable to provide documentation for Direct Loan reconciliations that had been completed during the year. Cause: Due to turnover within the Student Financial Aid Director position, and due to ongoing systematic issues with accessing the COD system, the Student Financial Aid Office was unable to provide sufficient documentation that Direct Loan reconciliations were submitted to the COD system during the year. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, if not completed on a regular basis, the College is at risk of not meeting disbursement reporting and excess cash deadlines. Questioned costs: None. Identification as a repeat finding: Yes. See finding 2024-003. Recommendation: The Student Financial Aid Office should develop, implement, and maintain a process to complete monthly Direct Loan reconciliations and retain associated support. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.

Corrective Action Plan

Western Wyoming Community College experienced unexpected turnover in the Director of Financial Aid position, which impacted financial aid reporting and reconciliation processes. Due to access issues with federal systems required for conducting reconciliations and the departure of a consultant who did not retain documentation for completed reconciliations, no reconciliations were available for review for the 2024/2025 Academic Year and 2025 Fiscal Year. Corrective Action Plan 1. Staffing and Training a. A new Director of Financial Aid has been hired and has completed training on the reconciliation process for both Pell Grants and Direct Loans in collaboration with the Assistant Director of Financial Aid. b. Cross-training has been implemented to ensure continuity of operations in the event of future staff turnover. 2. Establishment of Standard Operating Procedures (SOP) a. The Financial Aid Office has worked with the Business/Bursar’s Office to develop and document a Standard Operating Procedure (SOP) governing: • The drawdown of Title IV funds. • The reconciliation process for Pell and Direct Loan programs. b. The SOP outlines responsible parties, required documentation, and timelines for reconciliation and reporting. 3. Monthly Reconciliation Schedule a. A reconciliation schedule has been established requiring completion of Pell and Direct Loan reconciliations by the 15th of each month, or as soon thereafter as federal reports become available. b. Once reconciliations are confirmed as accurate and complete with the Business/Bursar’s Office, drawdowns of funds will occur on or near the 15th of each month, depending on calendar dates and federal system availability. 4. Compliance Alignment a. This process ensures timely and accurate reconciliation of Pell Grant and Direct Loan funding in accordance with 34 CFR 685.300(b)(5) and related federal cash management requirements. Anticipated Completion Date: November 15, 2025 Contact Persons: DeeAnna Archuleta, Director of Financial Aid, Assistant Director of Financial Aid, Business/Bursar’s Office

Categories

Student Financial Aid Cash Management Reporting

Other Findings in this Audit

  • 1166269 2025-001
    Material Weakness Repeat
  • 1166271 2025-003
    Material Weakness Repeat
  • 1166272 2025-003
    Material Weakness Repeat
  • 1166273 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $2.64M
84.268 FEDERAL DIRECT STUDENT LOANS $1.57M
84.334 GAINING EARLY AWARENESS AND READINESS FOR UNDERGRADUATE PROGRAMS $635,589
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $253,998
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $247,937
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $119,842
47.076 EDUCATION AND HUMAN RESOURCES $63,041
84.051 CAREER AND TECHNICAL EDUCATION -- NATIONAL PROGRAMS $39,966
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $32,535
84.033 FEDERAL WORK-STUDY PROGRAM $24,001
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $13,583
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $8,430