Finding 1201321 (2025-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 395955
Organization: University of San Diego (CA)

AI Summary

  • Core Issue: Seven students received Title IV funding despite being ineligible due to citizenship status, totaling $297,078 in disbursed funds.
  • Impacted Requirements: Compliance with 34 CFR sections 668.32(d) and 668.33 regarding citizenship and residency eligibility for federal aid.
  • Recommended Follow-Up: Implement a monitoring process to ensure the student financial aid system is correctly set up and functioning before processing student aid.

Finding Text

FINDING 2025-002 –Eligibility: Material Weakness in Internal Control Over Compliance (SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS - SECTION III - FINDING 2025-002 FOR INCLUDED TABLE) Criteria – 34 CFR section 668.32(d): A student is eligible to receive Title IV, HEA program assistance if the student either meets all of the requirements in paragraphs (a) through (m) of this section or meets the requirement in paragraph (n) of this section as follows: (d) Satisfies the citizenship and residency requirements contained in § 668.33 and subpart I of this part. 34 CFR section 668.33: Except as provided in paragraph (b) of this section, to be eligible to receive title IV, HEA program assistance, a student must—(1) Be a citizen or national of the United States; or (2) Provide evidence from the U.S. Immigration and Naturalization Service that he or she— (i) Is a permanent resident of the United States; or (ii) Is in the United States for other than a temporary purpose with the intention of becoming a citizen or permanent resident. Condition/Context – A sample of 70 students who were recipients of Title IV funding during the year were selected and the student records were compared student eligibility supporting documentation, disbursement documentation and FAFSA records. One student was identified during our testing whom was ineligible to receive Title IV funding as a result of their citizenship status. Upon further investigation by management, it was determined a total of 7 students had been awarded and disbursed Title IV funds during the year which were ineligible due to citizenship status. The total disbursed was determined to be $297,078 which was subsequently returned to the federal government. Effect – Students were disbursed funds when they were ineligible to receive such funds. Cause – The C-flag notifications within the student financial aid system for the law school was not properly set up at the start of the year and accordingly, certain C-flags, namely those related to citizenship were not relayed to the student aid processors within the law school. Repeat Finding – No Recommendation – We recommend the University of San Diego implement a process to monitor the system setup and evaluate it for proper functionality prior to when students are processed. Views of Responsible Officials– Management concurs with this finding and has established a new process by which there will be secondary verification of the student system setup completed annually.

Corrective Action Plan

Corrective Action Plan – Management concurs with this finding. During the student system set-up for academic year 2024-25, the appropriate screen was not properly updated with the new ISIR codes to set the tracking requirements to be posted for ISIR C Flags. Because the appropriate tracking documents were not posted, the system allowed the students to pass through packaging and disbursement. The Law School Financial Aid Office will implement a structured verification process as part of the student system setup for each academic year. Every step of the setup will be documented. To ensure accuracy, one staff member will complete the setup, and a separate staff member will independently review and verify the configuration. Management believes these enhancements will be sufficient to prevent future errors. Completion date: November 2025 Persons responsible: Vonda Garcia, Director of Law School Financial Aid

Categories

Eligibility Student Financial Aid Material Weakness

Other Findings in this Audit

  • 1201304 2025-001
    Material Weakness Repeat
  • 1201305 2025-001
    Material Weakness Repeat
  • 1201306 2025-001
    Material Weakness Repeat
  • 1201307 2025-001
    Material Weakness Repeat
  • 1201308 2025-001
    Material Weakness Repeat
  • 1201309 2025-001
    Material Weakness Repeat
  • 1201310 2025-001
    Material Weakness Repeat
  • 1201311 2025-001
    Material Weakness Repeat
  • 1201312 2025-001
    Material Weakness Repeat
  • 1201313 2025-002
    Material Weakness Repeat
  • 1201314 2025-002
    Material Weakness Repeat
  • 1201315 2025-002
    Material Weakness Repeat
  • 1201316 2025-002
    Material Weakness Repeat
  • 1201317 2025-002
    Material Weakness Repeat
  • 1201318 2025-002
    Material Weakness Repeat
  • 1201319 2025-002
    Material Weakness Repeat
  • 1201320 2025-002
    Material Weakness Repeat
  • 1201322 2025-003
    Material Weakness Repeat
  • 1201323 2025-003
    Material Weakness Repeat
  • 1201324 2025-003
    Material Weakness Repeat
  • 1201325 2025-003
    Material Weakness Repeat
  • 1201326 2025-003
    Material Weakness Repeat
  • 1201327 2025-003
    Material Weakness Repeat
  • 1201328 2025-003
    Material Weakness Repeat
  • 1201329 2025-003
    Material Weakness Repeat
  • 1201330 2025-003
    Material Weakness Repeat
  • 1201331 2025-003
    Material Weakness Repeat
  • 1201332 2025-003
    Material Weakness Repeat
  • 1201333 2025-003
    Material Weakness Repeat
  • 1201334 2025-003
    Material Weakness Repeat
  • 1201335 2025-003
    Material Weakness Repeat
  • 1201336 2025-003
    Material Weakness Repeat
  • 1201337 2025-003
    Material Weakness Repeat
  • 1201338 2025-003
    Material Weakness Repeat
  • 1201339 2025-003
    Material Weakness Repeat
  • 1201340 2025-003
    Material Weakness Repeat
  • 1201341 2025-003
    Material Weakness Repeat
  • 1201342 2025-003
    Material Weakness Repeat
  • 1201343 2025-003
    Material Weakness Repeat
  • 1201344 2025-003
    Material Weakness Repeat
  • 1201345 2025-003
    Material Weakness Repeat
  • 1201346 2025-003
    Material Weakness Repeat
  • 1201347 2025-003
    Material Weakness Repeat
  • 1201348 2025-003
    Material Weakness Repeat
  • 1201349 2025-003
    Material Weakness Repeat
  • 1201350 2025-003
    Material Weakness Repeat
  • 1201351 2025-003
    Material Weakness Repeat
  • 1201352 2025-003
    Material Weakness Repeat
  • 1201353 2025-003
    Material Weakness Repeat
  • 1201354 2025-003
    Material Weakness Repeat
  • 1201355 2025-003
    Material Weakness Repeat
  • 1201356 2025-003
    Material Weakness Repeat
  • 1201357 2025-003
    Material Weakness Repeat
  • 1201358 2025-003
    Material Weakness Repeat
  • 1201359 2025-003
    Material Weakness Repeat
  • 1201360 2025-003
    Material Weakness Repeat
  • 1201361 2025-003
    Material Weakness Repeat
  • 1201362 2025-003
    Material Weakness Repeat
  • 1201363 2025-003
    Material Weakness Repeat
  • 1201364 2025-003
    Material Weakness Repeat
  • 1201365 2025-003
    Material Weakness Repeat
  • 1201366 2025-003
    Material Weakness Repeat
  • 1201367 2025-003
    Material Weakness Repeat
  • 1201368 2025-003
    Material Weakness Repeat
  • 1201369 2025-003
    Material Weakness Repeat
  • 1201370 2025-003
    Material Weakness Repeat
  • 1201371 2025-003
    Material Weakness Repeat
  • 1201372 2025-003
    Material Weakness Repeat
  • 1201373 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS - UG $81.43M
84.268 FEDERAL DIRECT STUDENT LOANS - LS $26.39M
84.063 FEDERAL PELL GRANT PROGRAM $10.23M
84.038 FEDERAL PERKINS LOAN PROGRAM $2.47M
93.264 NURSE FACULTY LOAN PROGRAM (NFLP) $2.46M
84.033 FEDERAL WORK-STUDY PROGRAM $2.36M
12.800 SYNTHETIC AND CONSTRUCTIVE MATHEMATICS OF HIGHER STRUCTURES IN HOMOTOPY TYPE THEORY $1.47M
93.925 SCHOLARSHIPS FOR HEALTH PROFESSIONS STUDENTS FROM DISADVANTAGED BACKGROUNDS $660,000
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $648,253
93.732 IMPROVING ACCESS TO EFFECTIVE CHILD AND FAMILY SERVICES THROUGH INTEGRATED PRIMARY CARE $576,149
19.703 LITIGATION AND MEDIATION MEXICAN MOOT COURT $431,384
84.047 TRIO - UPWARD BOUND PROGRAM - HOOVER HS $408,782
47.076 ENGAGING WITH COMMUNITY FOR UNDERGRADUATE STUDENT SUCCESS IN MATHEMATICS, ENGINEERING AND SCIENCE $399,713
47.076 A CULTURALLY RELEVANT APPROACH TO SPATIAL COMPUTATIONAL THINKING SKILLS AND CAREER AWARENESS THROUGH AN IMMERSIVE VIRTUAL ENVIRONMENT $385,381
11.024 EDA BUILD TO SCALE - VILLAGE TO VENTURE $371,000
84.047 TRIO - UPWARD BOUND PROGRAM - KEARNY HS $337,442
16.030 NATIONAL CENTER ON RESTORATIVE JUSTICE (NCRJ) $320,761
21.027 COVID-19 USD CALIFORNIA VOLUNTEERS - CLIMATE ACTION SCHOLARSHIPS $308,472
84.217 TRIO - MCNAIR POST-BACCALAUREATE ACHIEVEMENT $291,909
84.367 CALIFORNIA GLOBAL EDUCATION PROJECT STATEWIDE OFFICE $284,631
16.030 NATIONAL CENTER ON RESTORATIVE JUSTICE - EXPANSION $253,116
84.116 UNIVERSITY OF SAN DIEGO VIOLENCE, INEQUALITY, AND POWER LAB FELLOWSHIP PROGRAM $245,980
93.859 NOVEL IN VITRO MICROSCOPY SUITE TO ELUCIDATE INTRACELLULAR TRANSPORT AND CONFORMATIONAL DYNAMICS OF NUCLEIC ACIDS $234,802
47.041 RET SITE: CLIMATE CHANGEMAKERS IN WASTE UPCYCLING, WATER JUSTICE AND SUSTAINABLE ENERGY $223,997
47.074 CAREER: EFFECTS OF PREGNANCY AND LACTATION ON MUSCLE-TENDOM FORM AND FUNCTION IN THE RAT - RATTUS NORVEGICUS $195,986
21.008 LOW-INCOME TAXPAYERS CLINICLS $194,207
47.076 RACIAL EQUITY: CO-CONSTRUCTING FACULTY CRITICAL CONSCIOUSNESS $183,834
19.703 ORAL ADVERSARIAL SKILL BUILDING INITIATIVE (OASIS) $147,280
47.074 RCN UBE: A NATIONAL MALATE DEHYDROGENASE PROTEIN-CENTRIC MOLECULAR LIFE SCIENCES COURSE-BASED UNDERGRADUATE RESEARCH NETWORK $133,544
47.074 CAREER: INTEGRATING FIELD EXPERIMENTS, MATHEMATICAL MODELS, AND INCLUSIVE EDUCATION TO UNDERSTAD ECOLOGICAL CONSEQUENCES OF VAIRATION IN HOST-PATHOGEN INTERACTIONS $133,200
47.049 RUI: PHOSPHORUS-DIRECTED C-H BORYLATION AND REACTIVITY OF PHOSPHABORANATES $118,882
66.046 SANDAG ON-CALL RESILIENCE SERVICES $115,241
47.050 LABORATORY SIMULATIONS OF CLOUD PROCESSING OF SMOKE $114,999
47.079 IRES: ARTIFICIAL INTELLIGENCE AND DATA SCIENCE FOR THE UNDERSTANDING, PREDICTION AND PREVENTION OF DISEASE (AI-UPP) $110,484
10.025 DIAGNOSTIC TOOLS FOR QUARANTINE SIGNIFICANT BEAN BEETLES IN THE OLD-WORLD GENUS CALLOSOBRUCHUS $108,152
59.037 BRINK SBDC: US SBA FY2024 $100,104
43.001 ZERO-G STUDIES OF FEW-BODY AND MANY-BODY PHYSICS- COLD ATOM LAB $100,000
47.079 COLLABORATIVE RESEARCH: RUI: IRES TRACK I: FROM FUNDAMENTAL TO APPLIED SOFT MATTER: RESEARCH EXPERIENCES IN MEXICO $91,181
47.076 IUSE: COLLABORATIVE RESEARCH: INTEGRATING SOCIATECHNICAL ISSUES IN ELECTRICAL ENGINEERING STARTING WITH CIRCUITS $89,055
43.001 ZERO-G STUDIES OF FEW BODY AND MANY BODY PHYSICS $86,063
47.049 REU SITE: MULTIDISCIPLNARY CHEMISTRY RESEARCH: EMPOWERING SCIENTISTS TO IMPROVE SOCIETY $77,260
47.049 COLLABORATIVE RESEARCH (RUI): UNDERSTANDING SHEATH FORMATION IN ELECTRONEGATIVE AND ELECTROPOSITIVE MULTIPLE ION SPECIES PLASMA, INCLUDING BOTH UNMAGNETIZED AND MAGNETIZED CASES $75,588
66.309 USA EPA ENERGY JUSTICE SUPPORT PROJECT $69,014
47.049 LEAPS-MPS: AN ULTRACOLD ATOM PLATFORM FOR UNDERGRADUATE TRAINING IN QUANTUM TECHNOLOGY $65,989
10.025 DEVELOPMENT OF GEOMETRIC MORPHOMETRICS $63,509
84.165 SAN DIEGO UNIFIED SCHOOL DISTRCITS'S VAPA AND MSAP GRANT $62,059
12.800 DESIGN AND REALTIME CHARACTERIZATION OF TOPOLOGICALY ACTIVE DNA-BASED MATERIALS $56,050
59.037 BRINK SBDC: US SBA FY2025 $55,604
84.165 MAGNET SCHOOLS ASSISTANCE PROGRAM GRANT TO CMPA AT SDUSD $49,833
47.041 STUDENT SUPPORT FOR THE AMERICAN SOCIETY FOR COMPOSITES (ASC) 39TH ANNUAL TECHNICAL CONFERENCE; SAN DIEGO, CALIFORNIA; 21-23 OCTOBER 2024 $45,999
47.076 THE ALLIANCE OF STUDENTS WITH DISABILITIES FOR INCLUSION, NETWORKING, AND TRANSITION OPPORTUNITIES IN STEAM (TAPDINTO-STEM) $44,428
43.001 CONSTRUCTING FREE ENERGY MAPS OF SULFUR-CONTAINING PROTOMETABILITES $37,204
47.049 RUI: TERPENSESAS VERSATILE BUILDING BLOCKS FOR MULTIVALENT POLYMERIC AND NANOPARTICLE SYSTEMS $36,719
84.206 PROJECT BRILLIANCE: DESIGNING IDENTIFICATION METHODS AND PROGRAMS FOR GIFTED STUDENTS WITH DISABILITIES $36,292
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $34,891
11.417 R/RCCE-18 UNDERSTANDING THE LONG-TERM PATTERNS OF CHANGE AND HISTORICAL ETHNOBOTANICAL USES OF TIDAL MARSHES IN NORTHERN MISSION BAY - SAN DIEGO - CALIFORNIA $27,945
47.049 COLLABORATIVE RESEARCH: DMREF: LIVING BIOTIC-ABIOTIC MATERIALS WITH TEMPORALLY PROGRAMMABLE ACTUATION $27,182
47.041 RESEARCH: COLLABORATIVE RESEARCH: SUSTAINING AND SCALING THE IMPACT OF THE MIDFIELD PROJECT AT THE AMERICAN SOCIETY FOR ENGINEERING EDUCATION $26,122
47.076 EXPANDQISE: TRACK 1: QUANTUM ANALOG SIMULATION WITH BOSE-EINSTEIN CONDENSATE IN FLEXIBLE LIGHT FIELDS $22,573
47.076 RACIAL EQUITY: STEM IN YOUR NEIGHBORHOODS: LEVERAGING COMMUNITY STORIES FROM PAST AND PRESENT OT DEFINE A NARRATIVE FOR THE FUTURE $22,388
47.049 RUI: QUANTUM KINETICS OF NEUTRINOS: STUDYING THE UNIVERSE AT THE INTERFACE OF NEUTRINO AND NUCLEAR ASTROPHYSICS $21,216
47.050 FOCUSED COPE: HEAT WAVES IN THE SOUTHERN CALIFORNIA COASTAL ZONE: THEIR OCEANIC AND ATMOSPHERIC DRIVERS, HUMAN HEALTH IMPACTS, AND SUSTAINABLE ADAPTATION $18,333
93.859 ECOLOGICAL AND EVOLUTIONARY CAUSES AND CONSEQUENCES OF HOST HETEROGENEITY INDUCED BY PRIOR EXPOSURE $16,541
47.049 RUI: QUANTUM KINETICS OF NEUTRINOS: LEVERAGING THE UNIVERSE AT THE NEUTRINO AND NUCLEAR ASTROPHYSICS $15,908
47.050 RUI: COLLABORATIVE RESEARCH: ASSESSING THE CAUSES OF THE PYROSOME INVASION AND PERSISTENCE IN THE CALIFORNIA CURRENT ECOSYSTEM $12,878
19.801 WOMEN'S INCLUSION FOR NEW SECURITY (WINS) $10,039
47.049 NATIONAL RESEARCH EXPERIENCES FOR UNDERGRADUATES PROGRAM $9,500
93.145 MIDWEST INTEGRATION OF THE NATIONAL HIV CIRRICULUM $9,124
47.079 IRES: TRACK I: US-SWEDEN CLINICAL BIOINFORMATICS RESEARCH TRAINING PROGRAM $7,561
21.027 COVID 19 FISCAL AGENT: LOVE LINDA VISTA, COMMUNITY FOOD GRANT PROGRAM $7,516
16.052 EVALUATING RESTORATIVE PRACTICES FOR DOMESTIC AND SEXUAL VIOLENCE: A COLLABORATIVE INITIATIVE $5,898
47.075 COLLABORATIVE RESEARCH: UNCOVERING AND ENHANCING PATHWAYS TO PSYCHOLOGICAL SAFETY AT WORK FOR RACIAL MINORITY WOMEN $5,624
47.076 COLLABORATIVE RESEARCH: FOSTERING ELEMENTARY SCHOOL STUDENTS' VISUOSPATIAL SKILLS AND MATHEMATICAL COMPETENCIEST THROUGH AN ORIGAMI-BASED PROGRAM $834
93.732 BEHAVIORAL HEALTH WORKFORCE EDUCATION AND TRAINING (BHWET) PROGRAM $298
47.050 COLLABORATIVE RESEARCH: GP-EXTRA: OCEANOGRAPHIC SHIPBOARD AND LAB RESEARCH FOR DIVERSE STUDENTS: EXPERIENTIAL LEARNING AS A GATEWAY TO GEOSCIENCE CAREERS $78
59.037 BRINK SBDC: US SBA FY2023 $66
11.008 NATIONAL OCEAN SCIENCES BOWL 2022 $15
84.425 COVID-19 ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF (ESSER) FUND $14
93.732 OPIOID WORKFORCE EXPANSION PROGRAM-PROFESSIONAL $5
47.049 RUI: PHOSPHINE-DIRECTED C-H BORYLATION: CATALYSIS DEVELOPMENT TO BIFUNCTIONAL LIGAND SYNTHESIS $-430
47.049 COLLABORATIVE RESEARCH: ACCESS EXPANSION: GROWING A NETWORK OF EQUITY-FOCUSED PROGRAMS IN HE PHYSICAL SCIENCES $-459
47.049 COLLABORATIVE RESEARCH: UNDERSTANDING SHEATHS AND PRE-SHEATHS IN MAGNETIZED AND UNMAGNETIZED PLASMAS $-650
47.079 COLLABORATIVE RESEARCH: RUI: IRES-TRACK I: BROWN CARBON AEROSOL FORMATION BY PHOTOOXIDATION OF PHENOLIC COMPOUNDS IN NANODROPLETS $-1,085
12.556 OCEANSIDE UNIFIED SCHOOL DISTRICT PROJECT SERVICE $-3,275