Finding 1172048 (2025-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-02-03
Audit: 385150
Organization: Southern California Seminary (CA)
Auditor: CAPINCROUSE LLC

AI Summary

  • Core Issue: The Seminary failed to keep necessary documents to support its FISAP reporting for the 2024-2025 financial aid year.
  • Impacted Requirements: This oversight violates 34 CFR 668.24(e), which mandates proper documentation retention.
  • Recommended Follow-Up: Ensure all supporting data for FISAP line items is retained according to the Seminary’s document retention policy.

Finding Text

FISAP Reporting Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.007 Federal Supplemental Educational Opportunity Grant Program, 84.033 Federal Work-Study Program, and 84.063 Federal Pell Grants Federal Award Identification #: 2024-2025 Financial Aid Year Condition: Document support used to complete FISAP was not retained to show evidence that the Seminary accurately reported items on the FISAP report. Criteria: 34 CFR 668.24(e) Questioned Costs: $0 Context: The Seminary did not properly retain underlying support on the FISAP reporting on award year 2024-2025. Cause: This was an oversight by management. Effect: The Seminary was unable to show evidence that they accurately reported items on the FISAP report. Identification as repeat finding, if applicable: Not Applicable Recommendation: We recommend the Seminary retain all data supporting all line items reported on the FISAP following the Seminary’s document retention policy. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

FISAP Reporting Planned Corrective Action: Deficiency: The backup documentation submitted for the Fiscal Operations Report and Application to Participate (FISAP) did not match the data reported on the FISAP. Institution Response: We acknowledge this discrepancy and agree that the FISAP backup documentation did not fully align with Part II, Sections 7a (Total Undergraduate Students) and 7b (Total Graduate Students) as reported on the submitted FISAP. The current FISAP reflects 43 for Section 7a, whereas the correct figure is 60, and 199 for Section 7b, whereas the correct figure is 202. Root Cause: At the time the report was prepared, the institution was relying on a contracted financial aid professional to provide the data for FISAP reporting. Although this work was performed in good faith, the contracted individual provided incorrect figures, which resulted in minor data discrepancies between the FISAP and the supporting documentation. Corrective Action Taken: Our Institution has ended its contract with the external financial aid services provider. We have transitioned all financial aid and FISAP-related responsibilities in-house and designated a qualified Data Point Administrator / Director of Financial Aid to oversee the preparation of the report. Additionally, there will be multiple financial professionals reviewing future FISAP and backup data. The current year’s FISAP has already been worked on using this updated structure, and all backup documentation has been reviewed for accuracy and confirmed to match the submitted FISAP. Preventive Measures Going Forward: To ensure accuracy and prevent recurrence, the institution has implemented the following procedures: 1. The Director of Financial Aid (Data Point Administrator) will prepare all FISAP data and maintain appropriate source documentation. 2. The Financial Aid Representative will review the completed FISAP and all backup documents to verify accuracy prior to submission. 3. The Financial Controller will receive the full FISAP packet, including backup documentation for an additional review and institutional oversight. 4. All FISAP materials and supporting documents will be stored in the institution’s secure Financial Aid OneDrive folder to ensure accessibility and consistency during audits. These steps have already been implemented for the most recent FISAP cycle and will be followed annually to maintain compliance and data integrity. Person Responsible for Corrective Action Plan: Josh James, CFO Anticipated Date of Completion: 11/24/2025

Categories

Student Financial Aid Reporting Significant Deficiency

Other Findings in this Audit

  • 1172046 2025-001
    Material Weakness Repeat
  • 1172047 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $816,518
84.063 FEDERAL PELL GRANT PROGRAM $40,717
84.033 FEDERAL WORK-STUDY PROGRAM $9,871
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $7,354