Finding 1168142 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-01-07
Audit: 379896
Organization: Liberty University, Inc. (VA)
Auditor: BDO USA PC

AI Summary

  • Core Issue: The University failed to verify certain information for 1 out of 20 students selected for federal aid verification, leading to non-compliance with federal regulations.
  • Impacted Requirements: Verification procedures outlined in 34 CFR Part 668 Subpart E were not followed, risking improper disbursement of federal awards.
  • Recommended Follow-Up: Enhance internal controls and quality control measures for verification processes, increase staff training, and implement regular data analysis to ensure compliance and accuracy.

Finding Text

Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (ALN 84.007), Federal Work- Study Program (ALN 84.033), Federal Pell Grant Program (ALN 84.063), Federal Direct Loan Program (ALN 84.268), and Teacher Education Assistance for College and Higher Education (“TEACH”) Grants (ALN 84.379) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Verification: For students selected for verification by the central processor, the institutions must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For a student selected for verification, certain information required to be verified did not match the underlying supporting documentation (including certain tax information). Cause: Administrative oversight and insufficient internal controls over verification requirements. Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations and the University was not in compliance with verification compliance requirements. Questioned Costs: None. Context: For 1 of 20 students selected for testing, the University did not complete appropriate verification procedures prior to disbursing aid. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that students are verified as required. Views of Responsible Officials: To strengthen compliance and ensure the accuracy of student aid eligibility determinations, we will enhance Liberty’s quality control (QC) measures within the federal verification process. Our primary goal is to minimize errors, improve consistency, and ensure all Financial Aid verification activities align with federal regulations and institutional policy. We will begin by implementing a more targeted QC process aimed at validating records of students who submitted subsequent tax documents. We will increase our verification QC selections of this particular population from 35% (current) to 60% (future) to verify data accuracy, documentation completeness, and adherence to ED’s Application and Verification Guide (AVG). Findings from these reviews will be used to identify training needs and process improvements. Staff training will be expanded to focus on federal verification requirements, common error trends, and documentation standards. Refresher trainings will be held with the entire verification processing team, and supplemental individual coaching will be provided on a monthly basis to address any specific issues identified through QC. We will also create reporting to ensure the percentage of reviews mentioned above is maintained by our QC workflow. Regular data analysis will help identify any systemic issues early, allowing for corrective actions to mitigate any compliance issues. By reinforcing staff training, system monitoring, and increased reviews, we will ensure that our federal verification process remains accurate, compliant, and student-centered.

Corrective Action Plan

Name of Responsible Individual: Matt Cooper, Student Financial Services Corrective Action: To strengthen compliance and ensure the accuracy of student aid eligibility determinations, we will enhance Liberty’s quality control (QC) measures within the federal verification process. Our primary goal is to minimize errors, improve consistency, and ensure all Financial Aid verification activities align with federal regulations and institutional policy. We will begin by implementing a more targeted QC process aimed at validating records of students who submitted subsequent tax documents. We will increase our verification QC selections of this particular population from 35% (current) to 60% (future) to verify data accuracy, documentation completeness, and adherence to ED’s Application and Verification Guide (AVG). Findings from these reviews will be used to identify training needs and process improvements. Staff training will be expanded to focus on federal verification requirements, common error trends, and documentation standards. Refresher trainings will be held with the entire verification processing team, and supplemental individual coaching will be provided on a monthly basis to address any specific issues identified through QC. We will also create reporting to ensure the percentage of reviews mentioned above is maintained by our QC workflow. Regular data analysis will help identify any systemic issues early, allowing for corrective actions to mitigate any compliance issues. By reinforcing staff training, system monitoring, and increased reviews, we will ensure that our federal verification process remains accurate, compliant, and student-centered. Anticipated Completion Date: February 2026

Categories

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring Eligibility Reporting

Other Findings in this Audit

  • 1168136 2025-001
    Material Weakness Repeat
  • 1168137 2025-001
    Material Weakness Repeat
  • 1168138 2025-002
    Material Weakness Repeat
  • 1168139 2025-002
    Material Weakness Repeat
  • 1168140 2025-002
    Material Weakness Repeat
  • 1168141 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $820.41M
84.063 FEDERAL PELL GRANT PROGRAM $161.20M
84.033 FEDERAL WORK-STUDY PROGRAM $7.45M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $5.09M
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $509,437
12.560 DOD, NDEP, DOTC-STEM EDUCATION OUTREACH IMPLEMENTATION $116,555
47.041 ENGINEERING $105,787
93.395 CANCER TREATMENT RESEARCH $36,016
93.855 ALLERGY AND INFECTIOUS DISEASES RESEARCH $6,925
12.902 INFORMATION SECURITY GRANTS $1,480