Finding 1204820 (2025-008)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 396458
Organization: Urshan College (MO)

AI Summary

  • Core Issue: The University lacks proper documentation for reviewing cash management reconciliations and drawdowns, leading to a significant deficiency in internal controls.
  • Impacted Requirements: This finding violates 2 CFR 200.303, which mandates that entities maintain internal controls to ensure compliance with federal laws and program requirements.
  • Recommended Follow-Up: The University should establish formal review procedures to ensure timely documentation of cash management reconciliations and drawdown reviews to prevent future compliance issues.

Finding Text

2025-008 Cash Management Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P248567 – 2025, P268K258567 – 2025, P268K256514 - 2025 Award Periods: July 1, 2024 through June 30, 2025 Type of Finding:  Significant Deficiency in Internal Control Over Compliance  Other Matters Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not have documentation that Direct Loan Reconciliations or Pell Reconciliations prepared by third-party servicer were reviewed. Additionally, we were unable to observe evidence that the University reviewed cash drawdowns prepared by the third party processor. Questioned Costs: None Context: During our testing, we reviewed 4 months of direct loan reconciliations that the University's third party servicer prepares; however, Urshan was unable to provide documentation of review for these reconciliations. Additionally, during our testing of 5 draws, we identified that all 5 draws did not have documented evidence of review. Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements. Repeat findings: 2024-009 Recommendation: We recommend that the University should implement formal review procedures to document that the Cash Management reconciliation and drawdown reviews are being performed to correct errors in a timely manner and to minimize the likelihood of errors going undetected. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

2025-008 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University should implement formal review procedures to document that the Cash Management reconciliation and drawdown reviews are being performed to correct errors in a timely manner and to minimize the likelihood of errors going undetected. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University performs cash management reconciliation and drawdown reviews; however, formal documentation of these reviews has not been consistently maintained. To address this, the University is implementing formal review procedures that include documented evidence of reconciliation and drawdown review activities. As part of this process, reconciliations and drawdowns prepared by FA Solutions will be reviewed by the Financial Aid Office for accuracy and completeness prior to submission and reporting. These procedures will be formalized within a standardized SOP, which will outline review timelines, responsibilities, and required documentation to ensure errors are identified and resolved in a timely manner and to reduce the risk of discrepancies going undetected. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 4/30/2026

Categories

Cash Management Matching / Level of Effort / Earmarking Student Financial Aid Significant Deficiency

Other Findings in this Audit

  • 1204808 2025-003
    Material Weakness Repeat
  • 1204809 2025-004
    Material Weakness Repeat
  • 1204810 2025-005
    Material Weakness Repeat
  • 1204811 2025-006
    Material Weakness Repeat
  • 1204812 2025-007
    Material Weakness Repeat
  • 1204813 2025-008
    Material Weakness Repeat
  • 1204814 2025-009
    Material Weakness Repeat
  • 1204815 2025-003
    Material Weakness Repeat
  • 1204816 2025-004
    Material Weakness Repeat
  • 1204817 2025-005
    Material Weakness Repeat
  • 1204818 2025-006
    Material Weakness Repeat
  • 1204819 2025-007
    Material Weakness Repeat
  • 1204821 2025-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $1.75M
84.063 FEDERAL PELL GRANT PROGRAM $1.24M
64.028 POST-9/11 VETERANS EDUCATIONAL ASSISTANCE $64,921
64.117 SURVIVORS AND DEPENDENTS EDUCATIONAL ASSISTANCE $8,250