Finding 1190924 (2025-005)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-03-27
Audit: 395202
Organization: Wilberforce University (OH)

AI Summary

  • Core Issue: Nine students were found ineligible for financial aid due to not meeting satisfactory academic progress, violating federal requirements.
  • Impacted Requirements: Compliance with federal regulations on academic progress is not being met, risking unallowable costs for the Institution.
  • Recommended Follow-Up: Enhance quality control procedures for financial aid reviews and ensure all staff are trained on federal regulations by June 30, 2026.

Finding Text

SCHEDULE OF FINDINGS AND QUESTIONED COSTS AND CORRECTIVE ACTION PLAN Federal Award Findings and Questioned Costs June 30, 2025 Comment 2025-005 PROCEDURES SHOULD BE IMPROVED TO ENSURE THAT STUDENTS ARE ELIGIBLE FOR STUDENT FINANCIAL AID STUDENT FINANCIAL AID CLUSTER PROGRAM CFDA # 84.268, 84.063, 84.007, and 84.038 (Questioned Costs-None) Condition: A student is not eligible to receive Title IV, HEA program assistance if the student has not maintained satisfactory academic progress in his or her course of study according to the Institution’s published standards of satisfactory progress that satisfy federal requirements. During our audit, we noticed nine (9) instances in our sample of sixty (60) in which a student did not meet satisfactory academic progress, qualitatively and/or quantitatively. Students were not put on academic status restrictions in a timely manner and in line with the Institution’s policies and procedures. Context: We reviewed the financial aid files of sixty (60) students selected for eligibility testing. Criteria: A student in receipt of Federal funds must maintain satisfactory academic progress in his or her course of study according to the Institution’s published standards of satisfactory progress that satisfy federal requirements [34 CFR 668.32 (f)]. Effect: Compliance with eligibility requirements as established in the Code of Federal Regulations are not met. Ineligible students may be receiving funds, resulting in additional charges to the Institution for unallowable costs. Cause: Transition to remote work environment as a result of the pandemic and inaccurate reviews of student files and miscalculation of financial awards. Recommendation: We recommend that the Institution improve its quality control procedures. Student financial aid award packages should be reviewed before aid is disbursed to ensure eligibility. Management should periodically perform monitoring activities to ensure that federal regulations are followed. All personnel involved in the compilation of the student financial aid packets should be aware of federal regulations which govern the requirements and procedures to be followed when awarding federal aid. Views of Responsible Officials and Planned Corrective Actions: During the FY21 fiscal year the University was sensitive to the significant amount of student concerns related to the abrupt transition from in class room learning to virtual learning environment. Many of them were not prepared for task virtual learning and did not have the proper equipment or experience with virtual learning because many of them had never done remote learning before. The concerns the University considered factors like student and faculty mental health, lack of resources, accessibility to the internet, etc. As a result, the University decided to provide some level of flexibility to the at-risk students and the SAP review process. Corrective action and improvements will be implemented by June 30, 2026 by the Director of Financial Aid.

Corrective Action Plan

ENROLLMENT REPORTING PROCEDURES SHOULD BE STRENGTHENED. STUDENT FINANCIAL AID CLUSTER PROGRAM ALN# 84.268,84.007,84.033, 84.063, and 84.038 (Questioned Costs - None) Views of Responsible Officials and Planned Corrective Actions The university will strengthen coordination between the Registrar, Financial Aid, and the Business Office to ensure that SAP status is evaluated and communicated before financial aid is disbursed. Procedures will be implemented to ensure timely receipt of grade reporting and academic alerts from faculty and Academic Affairs. Financial Aid staff will review SAP eligibility after each academic evaluation period and maintain documentation of SAP determinations. Students who do not meet SAP requirements will be appropriately flagged to ensure financial aid eligibility is addressed prior to disbursement, strengthening compliance with federal financial aid regulations. Date to be implemented: On-going and completed by June 1, 2026. Persons responsible: Vice President of Business & Finance and Office of Financial Aid.

Categories

Allowable Costs / Cost Principles Eligibility Student Financial Aid Subrecipient Monitoring

Other Findings in this Audit

  • 1190920 2025-005
    Material Weakness Repeat
  • 1190921 2025-005
    Material Weakness Repeat
  • 1190922 2025-005
    Material Weakness Repeat
  • 1190923 2025-005
    Material Weakness Repeat
  • 1190925 2025-004
    Material Weakness Repeat
  • 1190926 2025-004
    Material Weakness Repeat
  • 1190927 2025-004
    Material Weakness Repeat
  • 1190928 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $4.84M
84.063 FEDERAL PELL GRANT PROGRAM $4.05M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $1.40M
84.033 FEDERAL WORK-STUDY PROGRAM $1.14M
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $513,524
84.382 STRENGTHENING MINORITY-SERVING INSTITUTIONS $257,781
84.031 HIGHER EDUCATION INSTITUTIONAL AID $247,843
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $86,859