Finding 1175289 (2025-003)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-02-25
Audit: 389014
Organization: Hilbert College (NY)

AI Summary

  • Core Issue: The College failed to accurately code students' verification statuses in the COD system, leading to compliance concerns.
  • Impacted Requirements: This finding violates regulations outlined in 34 CFR 668.51 through 668.61 regarding the verification of student aid information.
  • Recommended Follow-Up: The College should revise its policies and procedures to ensure timely and accurate reporting of verification statuses to remain compliant.

Finding Text

2025–003 Verification Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.038, 84.033 Federal Award Identification Number and Year: P268K251853; 2025 Award Period: June 1, 2024 – May 31, 2025 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.51 through 668.61 states that the institution shall require applicants to verify any information used to calculate an applicant’s student aid index (SAI) that the institution has reason to believe is inaccurate and provide an accurate code for the individual’s verification status in the Common Origination and Disbursement (COD) system. Condition/Context: Student's verification status was not correctly coded in COD. Questioned costs: No. Cause: The College’s internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information reported to COD regarding student's verification status. Repeat Finding: No. Recommendation: The College should review its policies and procedures on reporting student's verification statuses to COD timely and accurately to be in compliance with regulations. Views of responsible officials: Please refer to the attached corrective action plan.

Corrective Action Plan

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: The College should review its policies and procedures on reporting student's verification statuses to COD timely and accurately to be in compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To ensure compliance, the College will implement the following corrective actions: 1. Policy Update: The Financial Aid Policies and Procedures will be revised to formally document procedures for reporting verification status updates to COD, including defined timelines and assigned responsibilities within the office. 2. Established Reporting Timeline: Verification status updates will be submitted to COD within ten business days of verification completion or any change impacting Pell eligibility. 3. Tracking and Oversight: A verification tracking log will be implemented to document completion dates and COD reporting dates within the Powerfaids system to ensure verification tasks are completed. 4. Staff Training: Financial aid staff will receive training in updated procedures and COD reporting requirements. These measures strengthen internal controls, enhance oversight, and ensure timely and accurate reporting of verification statuses to COD moving forward. Name(s) of the contact person(s) responsible for corrective action: Stephanie Schroeder, Director of Financial Aid Planned completion date for corrective action plan: Immediate action will take place, with the goal of implementing these changes effectively before the start of the new academic year.

Categories

Reporting Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1175275 2025-001
    Material Weakness Repeat
  • 1175276 2025-001
    Material Weakness Repeat
  • 1175277 2025-001
    Material Weakness Repeat
  • 1175278 2025-001
    Material Weakness Repeat
  • 1175279 2025-001
    Material Weakness Repeat
  • 1175280 2025-002
    Material Weakness Repeat
  • 1175281 2025-002
    Material Weakness Repeat
  • 1175282 2025-002
    Material Weakness Repeat
  • 1175283 2025-002
    Material Weakness Repeat
  • 1175284 2025-002
    Material Weakness Repeat
  • 1175285 2025-003
    Material Weakness Repeat
  • 1175286 2025-003
    Material Weakness Repeat
  • 1175287 2025-003
    Material Weakness Repeat
  • 1175288 2025-003
    Material Weakness Repeat
  • 1175290 2025-004
    Material Weakness Repeat
  • 1175291 2025-004
    Material Weakness Repeat
  • 1175292 2025-004
    Material Weakness Repeat
  • 1175293 2025-004
    Material Weakness Repeat
  • 1175294 2025-004
    Material Weakness Repeat
  • 1175295 2025-005
    Material Weakness Repeat
  • 1175296 2025-005
    Material Weakness Repeat
  • 1175297 2025-005
    Material Weakness Repeat
  • 1175298 2025-005
    Material Weakness Repeat
  • 1175299 2025-005
    Material Weakness Repeat
  • 1175300 2025-006
    Material Weakness Repeat
  • 1175301 2025-006
    Material Weakness Repeat
  • 1175302 2025-006
    Material Weakness Repeat
  • 1175303 2025-006
    Material Weakness Repeat
  • 1175304 2025-006
    Material Weakness Repeat
  • 1175305 2025-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $7.57M
84.063 FEDERAL PELL GRANT PROGRAM $3.41M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $71,019
84.033 FEDERAL WORK-STUDY PROGRAM $67,144
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $22,266