Finding 1174751 (2025-003)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
-
Year
2025
Accepted
2026-02-20
Audit: 388309
Organization: Clarkson College (NE)

AI Summary

  • Core Issue: The College lacks formal reviews for key financial processes, leading to a material weakness in internal controls over compliance with federal requirements.
  • Impacted Requirements: Compliance with 2 CFR section 200.303, which mandates effective internal controls for managing federal awards.
  • Recommended Follow-Up: The College should formalize and document its procedures to strengthen internal controls and ensure compliance throughout the academic year.

Finding Text

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Material Weakness in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, and FWS. Likewise, the College did not have a formal review of their award packaging during the 2024-25 academic year, R2T4 calculations, direct payment of FSA credit balances to students, and FISAP. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2024-25 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties. Effect or Potential Effect of Finding: The College is not in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: Yes, see finding 2024-002. Recommendation: We recommend the College review and formalize its procedures to ensure that internal controls are in place to identify and correct any inconsistencies throughout the year. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the College review and formalize its procedures to ensure that internal controls are in place to identify and correct any inconsistencies throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In the spring of 2025, Clarkson College made the decision to outsource majority of financial aid functions to the Higher Education Assistance Group (HEAG) due to a lack of internal controls. Since hiring HEAG in Spring 2025 to oversee our financial aid functions, Clarkson College has seen many improvements in our internal controls. Reconciliation of Direct Loans and Federal Pell Grant funds is conducted monthly by a designated Financial Aid staff member. Following completion, the reconciliation documentation is forwarded to the College Controller for independent review. Final approval is provided by the Vice President of Enrollment and Advising. A standing monthly meeting is also held between the Financial Aid and Finance teams to review reconciliation activity, address variances, and resolve any items requiring clarification. The Federal Work-Study (FWS) program is monitored and reviewed each pay period to ensure expenditures remain within authorized limits and align with student eligibility. Federal Supplemental Educational Opportunity Grant (FSEOG) and Federal Work-Study (FWS) funds are reviewed and reconciled periodically throughout each semester by a Financial Aid staff member. Upon completion of these reconciliations, supporting documentation is submitted to the College Controller for review and verification of accuracy. These procedures ensure compliance with federal regulations, promote internal control integrity, and provide appropriate oversight of all Title IV funding streams. Name(s) of the contact person(s) responsible for corrective action: Dr. Carla Dirkshneider, VP of Enrollment and Retention Planned completion date for corrective action plan: Corrective action was implemented Spring semester of FY 2025.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Material Weakness

Other Findings in this Audit

  • 1174736 2025-002
    Material Weakness Repeat
  • 1174737 2025-002
    Material Weakness Repeat
  • 1174738 2025-002
    Material Weakness Repeat
  • 1174739 2025-002
    Material Weakness Repeat
  • 1174740 2025-002
    Material Weakness Repeat
  • 1174741 2025-002
    Material Weakness Repeat
  • 1174742 2025-002
    Material Weakness Repeat
  • 1174743 2025-002
    Material Weakness Repeat
  • 1174744 2025-003
    Material Weakness Repeat
  • 1174745 2025-003
    Material Weakness Repeat
  • 1174746 2025-003
    Material Weakness Repeat
  • 1174747 2025-003
    Material Weakness Repeat
  • 1174748 2025-003
    Material Weakness Repeat
  • 1174749 2025-003
    Material Weakness Repeat
  • 1174750 2025-003
    Material Weakness Repeat
  • 1174752 2025-004
    Material Weakness Repeat
  • 1174753 2025-004
    Material Weakness Repeat
  • 1174754 2025-004
    Material Weakness Repeat
  • 1174755 2025-004
    Material Weakness Repeat
  • 1174756 2025-004
    Material Weakness Repeat
  • 1174757 2025-004
    Material Weakness Repeat
  • 1174758 2025-004
    Material Weakness Repeat
  • 1174759 2025-004
    Material Weakness Repeat
  • 1174760 2025-005
    Material Weakness Repeat
  • 1174761 2025-005
    Material Weakness Repeat
  • 1174762 2025-005
    Material Weakness Repeat
  • 1174763 2025-005
    Material Weakness Repeat
  • 1174764 2025-005
    Material Weakness Repeat
  • 1174765 2025-005
    Material Weakness Repeat
  • 1174766 2025-005
    Material Weakness Repeat
  • 1174767 2025-005
    Material Weakness Repeat
  • 1174768 2025-006
    Material Weakness Repeat
  • 1174769 2025-006
    Material Weakness Repeat
  • 1174770 2025-006
    Material Weakness Repeat
  • 1174771 2025-006
    Material Weakness Repeat
  • 1174772 2025-006
    Material Weakness Repeat
  • 1174773 2025-006
    Material Weakness Repeat
  • 1174774 2025-006
    Material Weakness Repeat
  • 1174775 2025-006
    Material Weakness Repeat
  • 1174776 2025-007
    Material Weakness Repeat
  • 1174777 2025-007
    Material Weakness Repeat
  • 1174778 2025-007
    Material Weakness Repeat
  • 1174779 2025-007
    Material Weakness Repeat
  • 1174780 2025-007
    Material Weakness Repeat
  • 1174781 2025-007
    Material Weakness Repeat
  • 1174782 2025-007
    Material Weakness Repeat
  • 1174783 2025-007
    Material Weakness Repeat
  • 1174784 2025-008
    Material Weakness Repeat
  • 1174785 2025-008
    Material Weakness Repeat
  • 1174786 2025-008
    Material Weakness Repeat
  • 1174787 2025-008
    Material Weakness Repeat
  • 1174788 2025-008
    Material Weakness Repeat
  • 1174789 2025-008
    Material Weakness Repeat
  • 1174790 2025-008
    Material Weakness Repeat
  • 1174791 2025-008
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $10.27M
84.063 FEDERAL PELL GRANT PROGRAM $1.43M
93.264 NURSE FACULTY LOAN PROGRAM (NFLP) $753,020
93.364 NURSING STUDENT LOANS $608,904
84.033 FEDERAL WORK-STUDY PROGRAM $42,196
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $33,497