Finding Text
Condition: The Institution prepared and submitted the FISAP without evidence of an independent, documented management review prior to submission. Criteria: Institutions participating in the Campus-Based programs are required to complete and submit the FISAP to the U.S. Department of Education by the applicable annual deadline, and to submit any required corrections/updates by established correction deadlines. In addition, institutions must establish, document, and maintain effective internal control over federal awards and evaluate and monitor compliance with statutes, regulations, and award terms. Cause: The condition occurred because management had not established or implemented formal procedures requiring an independent review of the FISAP prior to submission, nor did it require documentation evidencing such review. As a result, responsibilities for review and approval of the FISAP were not clearly defined or enforced. Effect: The condition occurred because management had not established or implemented formal procedures requiring an independent review of the FISAP prior to submission, nor did it require documentation evidencing such review. As a result, responsibilities for review and approval of the FISAP were not clearly defined or enforced. Repeat Finding: No. Recommendation: We recommend that the Institution establish and document a formal review and approval process over the preparation and submission of the FISAP. Views of Responsible Officials: We acknowledge the auditors’ recommendation regarding the implementation of a more formalized and documented review process for the FISAP prior to submission. While no errors or compliance findings were identified as a result of the current process, we understand the value of enhancing documentation to further evidence existing internal controls. It is important to note that, based on guidance and industry practice—including input from the U.S. Department of Education’s Regional Office of Participation (Southeast Region), the National Association of Student Financial Aid Administrators, and the Florida Association of Student Financial Aid Administrators—there is no regulatory requirement mandating an independent, formally documented review of the FISAP to demonstrate compliance with internal control standards. That said, in the spirit of continuous improvement and to address the auditors’ recommendation, management will enhance its existing review procedures as follows: • The Director of Financial Aid will continue to prepare and submit the FISAP in accordance with federal requirements. • As part of the established process, the Financial Aid Business Systems Analyst and Assistant Director of Financial Aid will continue to support the review by validating data accuracy, report outputs, and proper classification within the application. • To further strengthen documentation, a standardized review checklist will be implemented and retained to evidence the review process prior to submission. These enhancements are intended to formalize and document controls already in place, while aligning with the auditors’