Finding 1187016 (2025-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-03-26
Audit: 394728
Organization: University of Holy Cross (LA)
Auditor: EISNERAMPER LLP

AI Summary

  • Core Issue: A student received a direct subsidized loan exceeding their financial need, violating federal regulations.
  • Impacted Requirements: Total aid awarded must not exceed a student's financial need as defined by COA and SAI.
  • Recommended Follow-Up: Enhance controls over the financial aid process to ensure accurate COA and SAI reviews before disbursing loans.

Finding Text

Criteria: In accordance with the U.S. Department of Education’s regulations, awards must be coordinated among the various Title IV programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid awarded is not in excess of the student’s financial need or cost of attendance (“COA”) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). The determination of need-based student financial aid award amounts is based on financial need. Financial need is defined as the student’s COA minus the student’s student aid index (“SAI”) and other financial assistance. An overaward exists when a student’s financial aid exceeds the student’s need. Universe / Population: The universe / population for Eligibility is 567 student financial aid award recipients for the year ended June 30, 2025. We selected 60 student financial aid award recipients for testing of eligibility compliance requirements applicable to the program. Condition: In our sample of 60 student financial aid award recipients, we identified 1 incidence in which the student received a direct subsidized loan in excess of their financial need as determined by the institution’s COA calculation and the student’s SAI. The student’s total aid package exceeded the allowable financial need by $4,948. Cause: After the University’s initial financial need calculation was completed, the student received a scholarship that reduced their financial need. The University failed to properly update the student’s COA and/or other estimated financial assistance before disbursing the direct subsidized loan funds. Effect: Awarding aid in excess of a student's financial need results in noncompliance with federal regulations governing Title IV programs. The institution may be required to return the overawarded portion of direct subsidized loan funds to the U.S. Department of Education. Continued noncompliance may increase the risk of federal sanctions or additional oversight. Questioned Costs: $4,948 Repeat Finding: No Recommendation: We recommend that management strengthen controls over the financial aid awarding process, including implementing a more robust review of COA, SAI, and other estimated financial assistance prior to finalizing loan disbursements in order to not overaward financial assistance to students.

Corrective Action Plan

The Financial Aid Office identified suspicious activity in FY2025 and collaborated with IT and Admissions to verify the integrity of financial aid applications. The Financial Aid Office has implemented additional procedures and reporting controls to strengthen the financial aid awarding process. During the packaging process, a report is generated and reviewed to verify the Cost of Attendance (COA), Student Aid Index (SAI), and any other estimated financial assistance prior to loan disbursement. This review helps ensure that total financial aid does not exceed allowable limits and prevents the overawarding of aid to students.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $6.15M
84.063 FEDERAL PELL GRANT PROGRAM $1.22M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $59,850
84.033 FEDERAL WORK-STUDY PROGRAM $36,241