Finding 1171715 (2025-003)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2025
Accepted
2026-01-30
Audit: 384755
Organization: Simpson University (CO)
Auditor: CAPINCROUSE LLC

AI Summary

  • Core Issue: The University drew more Federal Direct Loan and Pell Grant funds than disbursed to students, leading to excess cash on hand for over 3 days.
  • Impacted Requirements: This violates cash management rules outlined in 34 CFR 668.162(a) and 34 CFR 668.162(c), risking potential interest owed to the Department of Education.
  • Recommended Follow-Up: Review disbursement reports to ensure compliance and return any excess cash over $500 to the Department of Education.

Finding Text

Cash Management Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Pell Grants and 84.268 Federal Direct Loans Federal Award Identification #: 2024-2025 Financial Aid Year Condition: The University initiated Federal Direct Loan (FDL) and Pell drawdowns from G5 for amounts greater than what had been disbursed to students, resulting in excess cash on hand for more than 3 days. Criteria: 34 CFR 668.162(a), 34 CFR 668.162(c) Questioned Costs: $0 Context: 2 FDL drawdowns out of 4 tested and 1 Pell drawdown out of 2 tested were greater than the amounts disbursed to students and therefore, not all disbursed within 3 days as required. The Pell overdraw occurred in September 2024 in the amount of $20,087 and was fully disbursed by October 2024. One FDL overdraw occurred in January 2025 in the amount of $52,389 and was fully disbursed by February 2025. One overdraw occurred at the end of April 2025 in the amount of $170,186 and wasn’t fully disbursed until June 2025. It was also noted that another drawdown for $550,000 in March 2025 wasn’t tied to any disbursements but was then returned in April 2025, 12 days later. Cause: Turnover and oversight by management. It appears that draws are being done based on what is authorized in G5 rather than the actual disbursement to student accounts. Effect: Non-compliance with cash management requirements to minimize the time between drawing the Title IV funds and disbursement of those funds to students. Cash on hand in excess of allowable levels and time frames may result in interest owed back to the Department of Education on excess cash. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University review student disbursements reports generated to ensure compliance with cash management requirements to disburse aid first before drawing FDL and Pell. We also recommend the University determine the amount of interest to be returned on the excess cash and return amounts greater than $500 to the Department of Education. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Cash Management Planned Corrective Action: The University agrees with the finding. The University determined that certain federal drawdowns during the audit period were initiated based on authorized amounts rather than confirmed student disbursements, resulting in excess cash on hand beyond allowable timeframes. To address this, the University has reviewed its cash management procedures and strengthened processes to ensure that federal funds are drawn only after student disbursements have been posted to student accounts. The University has reviewed the identified transactions, confirmed that excess funds were fully disbursed or returned as required, and will calculate and remit any applicable interest in accordance with federal regulations. Ongoing monitoring has been implemented to ensure drawdowns are consistently aligned with actual disbursement activity and compliance with cash management requirements is maintained. Person Responsible for Corrective Action Plan: Ken Macur, Interim Chief Financial Officer Anticipated Date of Completion: September 1, 2026

Categories

Student Financial Aid Cash Management

Other Findings in this Audit

  • 1171712 2025-002
    Material Weakness Repeat
  • 1171713 2025-002
    Material Weakness Repeat
  • 1171714 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $7.74M
84.063 FEDERAL PELL GRANT PROGRAM $2.33M
84.334 GAINING EARLY AWARENESS AND READINESS FOR UNDERGRADUATE PROGRAMS $426,061
84.047 TRIO UPWARD BOUND $302,850
84.042 TRIO STUDENT SUPPORT SERVICES $288,024
84.033 FEDERAL WORK-STUDY PROGRAM $135,176
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $75,260