Finding 1190928 (2025-004)

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

AI Summary

  • Core Issue: The University lacks regular reconciliation procedures for federal program funds, risking improper cash management.
  • Impacted Requirements: Compliance with federal financial management standards and timely reporting to the U.S. Department of Education and Commerce.
  • Recommended Follow-Up: Implement monthly reconciliations across departments, ensure oversight by responsible officials, and document compliance improvements by June 30, 2026.

Finding Text

SCHEDULE OF FINDINGS AND QUESTIONED COSTS Federal Award Findings and Questioned Costs June 30, 2025 Comment #2025-004 PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT OF FEDERAL PROGRAMS SHOULD BE IMPROVED CONNECTING MINORITY COMMUNITIES PROGRAM HIGHER EDUCATION EMERGENCY RELIEF FUND HIGHER EDUCATIONAL INSTITUTIONAL AID STRENGTHENING MINORITY-SERVING INSTITUTIONS U.S. DEPARTMENT OF EDUCATION ALN# 84.031B and E, 84.382, 84.425T U.S. DEPARTMENT OF COMMERCE ALN#11.028 (Questioned Costs - None) (Repeat 2024-004) Condition: Good internal controls over the receipt of federal funds require the reconciliation of authorized and recorded disbursements of cash drawn from the federal cash management system. This process ensures that federal funds are properly earned by the University and the University has not made a disbursement for which it has not been funded. During our audit, we noted that the University made efforts to reconcile its program activity under the Higher Educational Institutional Aid (Title III), Strengthening Minority-Serving Institutions and the Connecting Minority Communities Program. However, we did not see evidence that the reconciliation of the Title III program activity, Strengthening Minority -Serving Institutions and the Connecting Minority Communities Program is performed regularly as part of the University’s monthly and annual close-out. As a result, we noted the following: • The proper reconciliation of funds disbursed as allowed by the program requires reconciliation of the funds drawn and disbursed for each assistant listing portion (1) a reconciliation of funds disbursed to students directly (student aid portion) and funds disbursed for other allowable expenditures to the general ledger, (2) a reconciliation to the disbursement for general operating purposes and loss revenue to the approved and documented methodology and the general ledger accounts and (3) all funds requested via the G-5 reports should be accurately reconciled to the general ledger and to the various detail reports supporting the disbursements. This procedures also extends to the funds received from the Department of Commerce. The reconciliations should be summarized and reported quarterly and annually as required by the Department of Education and other funding sources. • Financial statement adjustments were needed to properly recognize the cash balance for the Title III program, Strengthening Minority-Serving Institutions and other programs. The reconciliation process, as outlined in the internal control procedures is not performed in a timely manner. Context: Review of cash management procedures related to the Title III-Strengthening Minority-Serving Institutions and the Connecting Minority Communities Program. Criteria: Standards for financial management systems [2 CFR §215.21]. (Continued) Effect: The effect is that unresolved balances could represent excess cash due back to the U.S. Department of Education, or not receipting funds that are due to the University for students who have obtained their education. Deficiency in reporting as required by the Department of Commerce. Cause: Weaknesses in procedures over reconciliation of grant activity. Recommendation: We recommend that management implement procedures to ensure that federal program activity is reconciled on a monthly basis for all open award years. This process should be coordinated between all affected departments (i.e., Grants and Contracts, Accounting Department, Sponsored Programs, Student Financial Aid, etc.). The reconciled amounts should properly reflect amounts due to or from the U.S. Department of Education and the U.S. Department of Commerce on the University’s general ledger accounting system. The reconciliations should be reviewed by a responsible official of the University. Monitoring of such reconciliation and the reporting requirements should be evidenced by internal control procedures and proper documentation of authorization. Views of Responsible Officials and Planned Corrective Actions: We concur with the auditor’s finding. The University has engaged a third party to review the reconciliation procedures and to make recommendations on improvements to our current policy. The recommendations will also include any additional documentation that showing proof that the reconciliation has been completed as timely as required. The Vice President of Business & Finance and the Director of Student Financial Aid will review the reconciliations. Monitoring reports will be completed and shared with senior management and relevant department leaders. Implementation date: Immediately and before June 30, 2026. Persons Responsible: Vice President of Business & Finance, controller and Director of Student Financial Aid.

Corrective Action Plan

COMMENT #2025-004 PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT OF FEDERAL PROGRAMS SHOULD BE IMPROVED. CONNECTING MINORITY COMMUNITIES PROGRAM HIGHER EDUCATION EMERGENCY RELIEF FUND HIGHER EDUCATIONAL INSTITUTIONAL AID STRENGTHENING MINORITY-SERVICING INSTITUTIONS U.S. DEPARTMENT OF EDUCATION ALN# 84.031 (B, E), 84.382G, 84.425T U.S. DEPARTMENT OF COMMERCE ALN# 11.028 (Questioned Costs –None )(Repeat) Views of Responsible Officials and Planned Corrective Actions The university will implement formal reconciliation procedures between federal financial aid systems and institutional accounting records. Reconciliation will occur between Banner, PowerFAIDS, G5 drawdown reports, and federal reporting systems including COD. These reconciliation procedures will be incorporated into the monthly financial closing process and will include review and participation from Financial Aid, the Business Office, and other appropriate administrative units. Documentation of reconciliation activity and supervisory review will be maintained to ensure compliance with federal requirements. Date to be implemented: On-going and completed by June 1, 2026. Persons responsible: Vice President of Business & Finance and Director of Financial Aid.

Categories

Cash Management Subrecipient Monitoring Reporting

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
  • 1190924 2025-005
    Material Weakness Repeat
  • 1190925 2025-004
    Material Weakness Repeat
  • 1190926 2025-004
    Material Weakness Repeat
  • 1190927 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