Finding 1205637 (2025-001)

Material Weakness Repeat Finding
Requirement
CELN
Questioned Costs
-
Year
2025
Accepted
2026-04-01
Audit: 397293
Organization: Tougaloo College (MS)

AI Summary

  • Core Issue: 16 out of 60 students did not meet Satisfactory Academic Progress (SAP), leading to potential ineligible Title IV funding.
  • Impacted Requirements: The College failed to monitor SAP as required by 34 CFR 668.34, resulting in a material weakness.
  • Recommended Follow-Up: Implement automated SAP tracking, establish a centralized appeal documentation system, and conduct annual evaluations to ensure compliance.

Finding Text

Finding 2025-001 - U.S. Department of Education (ED), Student Financial Assistance Programs – Satisfactory Academic Progress (material weakness): Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Federal Teacher Education Assistance for College (TEACH), FAL No. 84.379, June 30, 2025 Criteria – An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the Title IV, HEA programs. 34 CFR 668.34. Condition – We observed that 16 out of 60 students did not meet Satisfactory Academic Progress (SAP) for the Fall and Spring semesters. The College did not provide supporting documentation for successful appeals and allowed the students to receive Title IV student financial assistance funding. Cause – SAP was not properly monitored during the semester by responsible persons. This appears to have been an oversight. Effect – Ineligible students may have received Title IV federal student financial assistance funds. Questioned Costs – $346,764. Perspective – This is considered a systemic problem given the 16 exceptions noted from the sample of 60 students. Repeat Finding – Yes. Auditor's Recommendation – The College should evaluate all students at least annually to ensure they meet satisfactory academic progress. The frequency of the evaluation should be consistent with approved policies and procedures. This prevents ineligible students from possibly receiving Title IV federal student financial aid. Management’s Response – Tougaloo College acknowledges the findings identified in the audit for the fiscal year ending June 30, 2025, regarding Finding 2025-001 (Material Weakness). We recognize the gravity of the systemic issues related to the monitoring of Satisfactory Academic Progress (SAP) and the associated questioned costs of $346,764.00. The College is committed to full compliance with 34 CFR 668.34 and is implementing the following corrective actions to ensure the integrity of our Title IV Student Financial Aid Programs. • Automation and System Integration: The College is transitioning from manual SAP monitoring to an automated tracking system within our Student Information System (SIS). This will ensure that academic standing—specifically GPA and completion rates are calculated systematically at the end of each payment period. • Audit of Appeal Documentation: We are establishing a centralized digital repository for all SAP appeals. Effective immediately, no Title IV funds will be disbursed to students on financial aid probation without a documented, approved appeal and a corresponding academic plan on file. • Staff Training and Accountability: The Office of Financial Aid will undergo mandatory training focused specifically on federal SAP criteria. We have revised our internal "Check and Balance" protocol, requiring a secondary review by the Director of Financial Aid before any student failing SAP is cleared for disbursement. • Annual Policy Review: In alignment with the Auditor’s Recommendation, Tougaloo College will conduct a comprehensive annual evaluation of all students. This evaluation will be reconciled against the Registrar’s records to ensure data consistency. • We have updated our SAP policy to allow us to review at end of each Spring . The College has already begun the look-back process to review the eligibility of the 16 students identified in the sample. We anticipate that the new automated monitoring and revised internal controls will be fully operational by the start of the Spring 2026 semester to prevent any further repeat findings. View of Responsible Officials – The College agrees with the finding.

Corrective Action Plan

Finding 2025-001 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Satisfactory Academic Progress (material weakness): Management’s Response and Corrective Action Plan Tougaloo College acknowledges the findings identified in the audit for the fiscal year ending June 30, 2025, regarding Finding 2025-001 (Material Weakness). We recognize the gravity of the systemic issues related to the monitoring of Satisfactory Academic Progress (SAP) and the associated questioned costs of $346,764.00. The College is committed to full compliance with 34 CFR 668.34 and is implementing the following corrective actions to ensure the integrity of our Title IV Student Financial Aid Programs. • Automation and System Integration: The College is transitioning from manual SAP monitoring to an automated tracking system within our Student Information System (SIS). This will ensure that academic standing—specifically GPA and completion rates are calculated systematically at the end of each Spring Semester. • Audit of Appeal Documentation: We are establishing a centralized digital repository for all SAP appeals. Effective immediately, no Title IV funds will be disbursed to students on financial aid probation without a documented, approved appeal and a corresponding academic plan on file. • Staff Training and Accountability: The Office of Financial Aid will undergo mandatory training focused specifically on federal SAP criteria. We have revised our internal "Check and Balance" protocol, requiring a secondary review by the Director of Financial Aid before any student failing SAP is cleared for disbursement. • Annual Policy Review: In alignment with the Auditor’s Recommendation, Tougaloo College will conduct a comprehensive annual evaluation of all students. This evaluation will be reconciled against the Registrar’s records to ensure data consistency. • We have updated our SAP policy to allow us to review at end of each Spring The College has already begun the look-back process to review the eligibility of the 16 students identified in the sample. We anticipate that the new automated monitoring and revised internal controls will be fully operational by the start of the Fall 2026 semester to prevent any further repeat findings.

Categories

Student Financial Aid Eligibility Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness

Other Findings in this Audit

  • 1205605 2025-001
    Material Weakness Repeat
  • 1205606 2025-002
    Material Weakness Repeat
  • 1205607 2025-003
    Material Weakness Repeat
  • 1205608 2025-004
    Material Weakness Repeat
  • 1205609 2025-005
    Material Weakness Repeat
  • 1205610 2025-006
    Material Weakness Repeat
  • 1205611 2025-007
    Material Weakness Repeat
  • 1205612 2025-008
    Material Weakness Repeat
  • 1205613 2025-001
    Material Weakness Repeat
  • 1205614 2025-002
    Material Weakness Repeat
  • 1205615 2025-003
    Material Weakness Repeat
  • 1205616 2025-004
    Material Weakness Repeat
  • 1205617 2025-005
    Material Weakness Repeat
  • 1205618 2025-006
    Material Weakness Repeat
  • 1205619 2025-007
    Material Weakness Repeat
  • 1205620 2025-008
    Material Weakness Repeat
  • 1205621 2025-001
    Material Weakness Repeat
  • 1205622 2025-002
    Material Weakness Repeat
  • 1205623 2025-003
    Material Weakness Repeat
  • 1205624 2025-004
    Material Weakness Repeat
  • 1205625 2025-005
    Material Weakness Repeat
  • 1205626 2025-006
    Material Weakness Repeat
  • 1205627 2025-007
    Material Weakness Repeat
  • 1205628 2025-008
    Material Weakness Repeat
  • 1205629 2025-001
    Material Weakness Repeat
  • 1205630 2025-002
    Material Weakness Repeat
  • 1205631 2025-003
    Material Weakness Repeat
  • 1205632 2025-004
    Material Weakness Repeat
  • 1205633 2025-005
    Material Weakness Repeat
  • 1205634 2025-006
    Material Weakness Repeat
  • 1205635 2025-007
    Material Weakness Repeat
  • 1205636 2025-008
    Material Weakness Repeat
  • 1205638 2025-002
    Material Weakness Repeat
  • 1205639 2025-003
    Material Weakness Repeat
  • 1205640 2025-004
    Material Weakness Repeat
  • 1205641 2025-005
    Material Weakness Repeat
  • 1205642 2025-006
    Material Weakness Repeat
  • 1205643 2025-007
    Material Weakness Repeat
  • 1205644 2025-008
    Material Weakness Repeat
  • 1205645 2025-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $5.08M
84.063 FEDERAL PELL GRANT PROGRAM $3.18M
93.837 CARDIOVASCULAR DISEASES RESEARCH $1.25M
93.926 HEALTHY START INITIATIVE $1.11M
84.031 HIGHER EDUCATION_INSTITUTIONAL AID $883,162
84.044 TRIO_TALENT SEARCH $622,822
93.110 MATERNAL AND CHILD HEALTH FEDERAL CONSOLIDATED PROGRAMS $404,765
84.047 TRIO_UPWARD BOUND $369,909
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $303,476
84.066 TRIO_EDUCATIONAL OPPORTUNITY CENTERS $260,008
84.033 FEDERAL WORK-STUDY PROGRAM $235,716
81.049 OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM $229,246
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $199,710
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $186,071
90.200 DELTA REGIONAL AUTHORITY $183,663
47.083 INTEGRATIVE ACTIVITIES $129,475
97.061 CENTERS FOR HOMELAND SECURITY $116,874
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $116,436
93.307 MINORITY HEALTH AND HEALTH DISPARITIES RESEARCH $98,160
15.932 PRESERVATION OF HISTORIC STRUCTURES ON THE CAMPUSES OF HISTORICALLY BLACK COLLEGES AND UNIVERSITIES (HBCUS). $71,592
12.750 UNIFORMED SERVICES UNIVERSITY MEDICAL RESEARCH PROJECTS $69,234
16.525 GRANTS TO REDUCE DOMESTIC VIOLENCE, DATING VIOLENCE, SEXUAL ASSAULT, AND STALKING ON CAMPUS $57,594
93.389 NATIONAL CENTER FOR RESEARCH RESOURCES $47,697
84.184 SAFE AND DRUG-FREE SCHOOLS AND COMMUNITIES_NATIONAL PROGRAMS $47,603
97.008 NON-PROFIT SECURITY PROGRAM $37,400
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $35,834
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $30,268
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $23,639
10.675 URBAN AND COMMUNITY FORESTRY PROGRAM $23,593
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $15,346
93.421 STRENGTHENING PUBLIC HEALTH SYSTEMS AND SERVICES THROUGH NATIONAL PARTNERSHIPS TO IMPROVE AND PROTECT THE NATION’S HEALTH $9,891
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $1,121
10.331 GUS SCHUMACHER NUTRITION INCENTIVE PROGRAM $1,032