Finding 1210653 (2024-015)

Material Weakness Repeat Finding
Requirement
CELN
Questioned Costs
-
Year
2024
Accepted
2026-04-28

AI Summary

  • Core Issue: There are inconsistencies between Title IV award letters and actual disbursements for 21.7% of students, indicating a systemic problem.
  • Impacted Requirements: The University is not meeting federal notification requirements under 34 CFR § 668.165 (a) and is failing to maintain administrative capability as per 34 CFR § 668.18.
  • Recommended Follow-Up: Implement monthly reconciliations, enhance cross-department coordination, and conduct year-end reconciliations to ensure compliance and improve internal controls.

Finding Text

Finding 2024-015 - U.S. Department of Education (USDJ, Title IV Student Financial Aid Programs - Inconsistencies Between Award Letters and Actual Title IV Disbursements (material weakness): Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2024; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2024; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2024; Federal Work-Study Program, FAL No. 84.033, June 30, 2024. Criteria – Per 34 CFR § 668.165 (a), institutions must notify a student or parent of a PLUS borrower, of the amount and type of Title IV funds the student will receive and ensure the information provided is accurate and consistent with actual disbursements. Condition – During testing of student financial aid records, we identified that thirteen (13) out of sixty (60) students had inconsistencies between the Title IV award amounts listed on their financial aid award letters and the amounts actually disbursed to their student account statements. Differences included Pell Grant, Direct Loan, and campus-based aid amounts that did not match the final disbursements reflected in the University’s student account system. Cause – The inconsistencies appear to have resulted from failure to update award letters. Effect – Students received incorrect or misleading information about their financial aid eligibility. Discrepancies can result in over awards or under awards of Title IV funds, improper loan disbursements and the University is not meeting administrative capability requirements under 34 CFR § 668.18. Questioned Costs - $0 Perspective – A discrepancy rate of 13 out of 60 students (21.7%) indicates a systemic issue, not isolated clerical errors. Because award letters are the official communication of eligibility and expected aid, inconsistencies undermine transparency, violate federal notification requirements, and reflect weaknesses in the University’s internal controls over awarding and disbursement. Repeat Finding - No Auditor’s Recommendation - The University should implement monthly reconciliations, strengthen cross-department coordination, perform year-end reconciliation prior to FISAP submission. Implementation of these measures will help ensure compliance with federal regulations, reduce financial reporting risk, and reinforce the University’s administrative capability. Management’s Response – Management has added secondary review, implemented periodic internal monitoring, and enhanced system controls within the financial aid software. View of Responsible Officials – Management agrees with the finding and acknowledges that discrepancies occurred between information reflected on award letters and actual Title IV disbursements, resulting in inconsistent communication of federal aid information to students and parents.

Corrective Action Plan

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-015 1. Finding Summary The auditor determined that information reflected on student award letters was not always consistent with actual Title IV disbursements. As a result, the institution could not fully demonstrate compliance with federal notification requirements to ensure students and parents received accurate and reliable information regarding Title IV aid awards and disbursements. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that discrepancies occurred between information reflected on award letters and actual Title IV disbursements, resulting in inconsistent communication of federal aid information to students and parents. 3. Root Cause Analysis The root cause of this finding resulted from insufficient supervisory or secondary review to ensure award letters were updated prior to processing or disbursement, limited internal monitoring and quality assurance over award communications, and system configuration limitations that affected the timely alignment of award letters with actual Title IV disbursements. 4. Corrective Action(s) Management has added secondary review, implemented periodic internal monitoring, and enhanced system controls within the financial aid software. Description of Corrective Actions A required supervisory or secondary review has been added to confirm award letter accuracy before processing or disbursement, periodic internal monitoring and quality assurance reviews have been implemented to ensure consistency between award letters and Title IV disbursements, and system controls within the financial aid software have been strengthened to improve data alignment and accuracy. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions mitigate the risk of discrepancies between award letters and actual Title IV disbursements by strengthening oversight, improving system accuracy, and ensuring timely review and validation of award communications. Ongoing monitoring and quality assurance reviews further reduce the likelihood of inaccurate student notifications and support sustained compliance with federal Title IV disclosure requirements. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Director of Financial Aid • Name (optional): ______ 7. Implementation Timeline • Corrective action implemented: Yes (No) • If not fully implemented, expected completion date: June 30, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) Fully implemented Partially implemented (Not yet implemented) Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability The corrective actions will be monitored through ongoing supervisory review and periodic internal quality assurance checks to confirm award letter accuracy before Title IV processing and disbursements. These practices will be sustained through standardized review procedures and continued oversight to ensure long-term compliance and timely correction of any documentation deficiencies.

Categories

Student Financial Aid

Other Findings in this Audit

  • 1210606 2024-004
    Material Weakness Repeat
  • 1210607 2024-004
    Material Weakness Repeat
  • 1210608 2024-004
    Material Weakness Repeat
  • 1210609 2024-004
    Material Weakness Repeat
  • 1210610 2024-005
    Material Weakness Repeat
  • 1210611 2024-005
    Material Weakness Repeat
  • 1210612 2024-005
    Material Weakness Repeat
  • 1210613 2024-005
    Material Weakness Repeat
  • 1210614 2024-006
    Material Weakness Repeat
  • 1210615 2024-006
    Material Weakness Repeat
  • 1210616 2024-006
    Material Weakness Repeat
  • 1210617 2024-006
    Material Weakness Repeat
  • 1210618 2024-007
    Material Weakness Repeat
  • 1210619 2024-007
    Material Weakness Repeat
  • 1210620 2024-007
    Material Weakness Repeat
  • 1210621 2024-007
    Material Weakness Repeat
  • 1210622 2024-008
    Material Weakness Repeat
  • 1210623 2024-008
    Material Weakness Repeat
  • 1210624 2024-008
    Material Weakness Repeat
  • 1210625 2024-008
    Material Weakness Repeat
  • 1210626 2024-009
    Material Weakness Repeat
  • 1210627 2024-009
    Material Weakness Repeat
  • 1210628 2024-009
    Material Weakness Repeat
  • 1210629 2024-009
    Material Weakness Repeat
  • 1210630 2024-010
    Material Weakness Repeat
  • 1210631 2024-010
    Material Weakness Repeat
  • 1210632 2024-010
    Material Weakness Repeat
  • 1210633 2024-010
    Material Weakness Repeat
  • 1210634 2024-011
    Material Weakness Repeat
  • 1210635 2024-011
    Material Weakness Repeat
  • 1210636 2024-011
    Material Weakness Repeat
  • 1210637 2024-011
    Material Weakness Repeat
  • 1210638 2024-012
    Material Weakness Repeat
  • 1210639 2024-012
    Material Weakness Repeat
  • 1210640 2024-012
    Material Weakness Repeat
  • 1210641 2024-012
    Material Weakness Repeat
  • 1210642 2024-013
    Material Weakness Repeat
  • 1210643 2024-013
    Material Weakness Repeat
  • 1210644 2024-013
    Material Weakness Repeat
  • 1210645 2024-013
    Material Weakness Repeat
  • 1210646 2024-014
    Material Weakness Repeat
  • 1210647 2024-014
    Material Weakness Repeat
  • 1210648 2024-014
    Material Weakness Repeat
  • 1210649 2024-014
    Material Weakness Repeat
  • 1210650 2024-015
    Material Weakness Repeat
  • 1210651 2024-015
    Material Weakness Repeat
  • 1210652 2024-015
    Material Weakness Repeat
  • 1210654 2024-016
    Material Weakness Repeat
  • 1210655 2024-016
    Material Weakness Repeat
  • 1210656 2024-016
    Material Weakness Repeat
  • 1210657 2024-016
    Material Weakness Repeat
  • 1210658 2024-017
    Material Weakness Repeat
  • 1210659 2024-017
    Material Weakness Repeat
  • 1210660 2024-017
    Material Weakness Repeat
  • 1210661 2024-017
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $4.86M
84.063 FEDERAL PELL GRANT PROGRAM $3.98M
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $1.28M
84.031 HIGHER EDUCATION_INSTITUTIONAL AID $640,518
93.658 FOSTER CARE_TITLE IV-E $222,374
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $146,410
84.184 SAFE AND DRUG-FREE SCHOOLS AND COMMUNITIES_NATIONAL PROGRAMS $97,937
47.076 EDUCATION AND HUMAN RESOURCES $49,977
93.307 MINORITY HEALTH AND HEALTH DISPARITIES RESEARCH $34,071
84.033 FEDERAL WORK-STUDY PROGRAM $21,362
12.903 GENCYBER GRANTS PROGRAM $16,783
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $15,000
47.083 INTEGRATIVE ACTIVITIES $3,631