Finding 1176559 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-05
Audit: 390365
Organization: Johnson C. Smith University (NC)
Auditor: BDO USA PC

AI Summary

  • Core Issue: The University failed to notify certain students about their Title IV funds before disbursing them, violating federal requirements.
  • Impacted Requirements: Compliance with award notification rules under 34 CFR 668.165(a)(1) was not met, affecting the disbursement process.
  • Recommended Follow-Up: Enhance internal controls and procedures to ensure timely award notifications are sent before any Title IV fund disbursements.

Finding Text

Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), and Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Disbursements To or On Behalf of Students - Notification of Disbursement – Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)). Condition: Certain students were not notified of the amount and type of Title IV funds they were expected to receive prior to the University disbursing Title IV funds to the student. Cause: Insufficient administrative oversight and internal controls with respect to award notifications. Effect or Potential Effect: The University was not in compliance with award notification requirements. Questioned Costs: None. Context: For 1 of 25 students tested, an award notification was not sent to the student prior to the student receiving their first disbursement of Title IV funds. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its internal controls and policies and procedures over Title IV award notifications to ensure such notifications are sent to students prior to the University disbursing aid. Views of Responsible Officials: Johnson C. Smith University acknowledges that, for one student tested, an award notification was not issued prior to the initial disbursement of Title IV funds, as required by federal regulations. Although an award notification was subsequently generated, all Title IV aid for this student had already been disbursed prior to issuance of the notification. The University determined that this exception resulted from insufficient internal controls governing the award notification process within PowerFAIDS, including the absence of a reliable audit trail to document the timing and issuance of award notifications relative to disbursement activity. Contributing factors included reliance on manual processes and limited system-enforced sequencing controls, which reduced the University’s ability to consistently verify that required notifications were issued prior to disbursement.

Corrective Action Plan

Corrective Action Plan: To address the deficiency identified in Finding 2025-003, the University has implemented and is continuing to formalize corrective actions focused on strengthening award notification sequencing, automating required communications, and ensuring a verifiable audit trail prior to the disbursement of Title IV funds. Primary Control Enhancements. With the assistance of Financial Aid Services (FAS), Ellucian Colleague has been configured to automate award notification generation upon completion of student packaging, creating a system-generated audit trail that documents notification timing relative to disbursement. This automation ensures that award notifications are issued prior to disbursement activity and creates a system-generated audit trail documenting the timing and issuance of the notification. Supporting Controls and Training. Financial Aid staff receive ongoing system and compliance training to reinforce proper sequencing of notifications and disbursements. Monitoring and Quality Assurance. Routine quality assurance reviews confirm that award notifications are issued and documented prior to disbursement, with exceptions documented and corrected. Sustained Oversight. Any exceptions identified will be reviewed, documented, and corrected to ensure sustained compliance. Anticipated Completion Date: June 2026

Categories

Student Financial Aid Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1176550 2025-001
    Material Weakness Repeat
  • 1176551 2025-001
    Material Weakness Repeat
  • 1176552 2025-001
    Material Weakness Repeat
  • 1176553 2025-001
    Material Weakness Repeat
  • 1176554 2025-002
    Material Weakness Repeat
  • 1176555 2025-002
    Material Weakness Repeat
  • 1176556 2025-003
    Material Weakness Repeat
  • 1176557 2025-003
    Material Weakness Repeat
  • 1176558 2025-003
    Material Weakness Repeat
  • 1176560 2025-004
    Material Weakness Repeat
  • 1176561 2025-005
    Material Weakness Repeat
  • 1176562 2025-005
    Material Weakness Repeat
  • 1176563 2025-005
    Material Weakness Repeat
  • 1176564 2025-006
    Material Weakness Repeat
  • 1176565 2025-006
    Material Weakness Repeat
  • 1176566 2025-006
    Material Weakness Repeat
  • 1176567 2025-007
    Material Weakness Repeat
  • 1176568 2025-007
    Material Weakness Repeat
  • 1176569 2025-008
    Material Weakness Repeat
  • 1176570 2025-008
    Material Weakness Repeat
  • 1176571 2025-008
    Material Weakness Repeat
  • 1176572 2025-008
    Material Weakness Repeat
  • 1176573 2025-008
    Material Weakness Repeat
  • 1176574 2025-008
    Material Weakness Repeat
  • 1176575 2025-009
    Material Weakness Repeat
  • 1176576 2025-009
    Material Weakness Repeat
  • 1176577 2025-009
    Material Weakness Repeat
  • 1176578 2025-010
    Material Weakness Repeat
  • 1176579 2025-010
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $12.35M
84.063 FEDERAL PELL GRANT PROGRAM $6.16M
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $2.38M
84.031 HIGHER EDUCATION INSTITUTIONAL AID $499,663
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $457,333
84.120 MINORITY SCIENCE AND ENGINEERING IMPROVEMENT $401,852
84.033 FEDERAL WORK-STUDY PROGRAM $388,738
84.047 TRIO UPWARD BOUND $369,588
84.042 TRIO STUDENT SUPPORT SERVICES $366,285
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $269,267
84.217 TRIO MCNAIR POST-BACCALAUREATE ACHIEVEMENT $232,533
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $201,323
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $185,839
93.391 ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES $48,474
89.003 NATIONAL HISTORICAL PUBLICATIONS AND RECORDS GRANTS $46,856
97.062 SCIENTIFIC LEADERSHIP AWARDS $26,250
97.061 CENTERS FOR HOMELAND SECURITY $15,207
11.417 SEA GRANT SUPPORT $5,250
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $4,800
93.310 TRANS-NIH RESEARCH SUPPORT $2,000
17.268 H-1B JOB TRAINING GRANTS $1,078
54.001 INTELLIGENCE COMMUNITY CENTERS FOR ACADEMIC EXCELLENCE $773