Finding 1225352 (2025-003)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-07-31
Audit: 408332
Organization: Gallaudet University (DC)

AI Summary

  • Core Issue: The University failed to retain sufficient documentation to support key reported figures in the FISAP, leading to inaccuracies and potential noncompliance.
  • Impacted Requirements: Key line items such as total tuition and fees, eligible aid applicants, and Federal Pell Grant expenditures were not substantiated, risking incorrect reporting.
  • Recommended Follow-Up: Strengthen procedures for documentation retention and implement a review process to ensure all reported information is supported by adequate records.

Finding Text

FINDING 2025-003 Internal Control over Compliance and Compliance with Reporting (Significant Deficiency and Noncompliance) Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Number: Federal Supplemental Educational Opportunity Grant (84.007A), Federal Pell Grant (84.063P), and Federal Work Study (84.033A) Criteria: The Fiscal Operations Report and Application to Participate (FISAP) is used by schools to apply for Campus-Based Program funding for the upcoming award year and to report Campus-Based Program expenditures for the previous award year (34 CFR 674.19, 34 CFR 675.19, 34 CFR 676.19 and 20 U.S.C 1094). Key line items on the FISAP include: Part II (Application), Section E, Line 22: Total tuition and fees; Part II (Application), Section E, Line 23: Total Federal Pell Grant expenditures; Part II (Application), Section F, Lines 25-39: Information on eligible aid applicants; Part IV (FSEOG), Section C, Lines 12-14: Funds to FSEOG recipients; and Part V (FWS), Section C, Lines 12-14: Total compensation for FWS. The University is responsible for maintaining sufficient records to support the completeness and accuracy of information reported in the FISAP. Condition: The University reported the information in the key line items noted above in the FISAP, however, it did not retain sufficient supporting documentation to substantiate certain reported information. Specifically, the University was unable to provide the underlying source data supporting: (1) total tuition and fees for the award year July 1, 2024 to June 30, 2025; (2) information on eligible aid applicants enrolled for award year 2024-25; and (3) nonfederal share of funds to FSEOG recipients. In addition, the total Federal Pell Grant expenditures for the 2024-2025 award year reported by the University in the FISAP did not reconcile to the University’s final Federal Pell Grant closeout balances. Effect or Potential Effect: As a result, the University could not demonstrate the completeness and accuracy of the reported information included within the key line items noted above. The lack of appropriate processes to accumulate and maintain the relevant supporting documentation used to prepare the FISAP increases the risk that inaccurate or incomplete information could be reported without detection and may result in noncompliance with the FISAP reporting requirements. In addition, the total Federal Pell Grant expenditures for the 2024-2025 award year reported in the FISAP were overstated by $97,915. Context: During testing of the University's FISAP, the audit team tested key line items subject to the reporting requirements. No supporting documentation was available to support the: (1) total tuition and fees for the award year July 1, 2024 to June 30, 2025; (2) information on eligible aid applicants enrolled for the award year 2024-25; and (3) the nonfederal share of funds to FSEOG recipients. In addition, the total Federal Pell Grant expenditures for the 2024-2025 award year reported in the FISAP totaled $3,348,864 while the Federal Pell Grant expenditures for the 2024-2025 award year per the University’s records totaled $3,250,949. Cause: The University did not maintain the underlying source reports, supporting schedules, or other documentation used to compile certain information included in the FISAP. As a result, the data used to prepare the disclosures could not be recreated or validated subsequent to the report's submission. In addition, when the FISAP was being prepared, the University had recently implemented a new enterprise planning system and certain financial aid internal controls and reconciliation processes were still being established. Questioned Costs: None identified. Recommendation: We recommend that the University strengthen its procedures for accumulating, preparing and retaining support for the FISAP. Specifically, management should retain the source reports, supporting schedules, calculations, and other relevant documentation used to compile reported information and implement a review process to verify that supporting documentation is maintained and readily available to substantiate all reported information. Views of Responsible Official: Management’s corrective action plan, including immediate remediation steps and enhancements to internal controls over Reporting, is presented in the Corrective Action Plan section of this report.

Corrective Action Plan

FINDING 2025-003 Internal Control over Compliance and Compliance with Reporting (Significant Deficiency and Noncompliance) Responsive to finding: We agree with the finding. Corrective Action Plan: Gallaudet University will continue to enhance its procedures for the preparation, reconciliation, review, and retention of supporting documentation related to the Fiscal operations Report and Application to Participate (FISAP) to ensure that all reported information is complete, accurate, adequately supported, and retained in accordance with federal requirements. The University will implement the following corrective actions: • Continue to refine FISAP preparation procedures by clearly identifying the source reports, calculations, reconciliations, review requirements, and supporting documentation necessary for key reporting line items to promote consistency, accuracy, and supportability of reported information. • Enhance documentation retention practices by maintaining a centralized electronic repository for FISAP-related source reports, supporting schedules, reconciliations, calculations, and review documentation to ensure supporting records are readily available for review and audit purposes. • Continue to strengthen reconciliation procedures by requiring documented reconciliation of key FISAP data elements, including Pell Grant expenditures, tuition and fee information, eligible applicant data, and campus-based program expenditures, to supporting financial aid records, federal reporting records, and the general ledger prior to submission. • Enhance supervisory review procedures to verify the completeness, accuracy, and supportability of information reported in the FISAP before certification and submission to the U.S. Department of Education. • Conduct periodic monitoring of FISAP preparation and documentation retention practices to verify compliance with established procedures and identify opportunities for continuous improvement. These corrective actions will further strengthen the University's internal controls over federal reporting and help ensure ongoing compliance with FISAP reporting requirements and documentation retention standards. Individual(s) Responsible for Corrective Action Plan: Amanda Jackson, Director of Financial Aid John Skjeveland, Controller Estimated Completion Date: September 30, 2026

Categories

Student Financial Aid

Other Findings in this Audit

  • 1225301 2025-001
    Material Weakness Repeat
  • 1225302 2025-001
    Material Weakness Repeat
  • 1225303 2025-002
    Material Weakness Repeat
  • 1225304 2025-002
    Material Weakness Repeat
  • 1225305 2025-002
    Material Weakness Repeat
  • 1225306 2025-002
    Material Weakness Repeat
  • 1225307 2025-002
    Material Weakness Repeat
  • 1225308 2025-002
    Material Weakness Repeat
  • 1225309 2025-002
    Material Weakness Repeat
  • 1225310 2025-002
    Material Weakness Repeat
  • 1225311 2025-002
    Material Weakness Repeat
  • 1225312 2025-002
    Material Weakness Repeat
  • 1225313 2025-002
    Material Weakness Repeat
  • 1225314 2025-002
    Material Weakness Repeat
  • 1225315 2025-002
    Material Weakness Repeat
  • 1225316 2025-002
    Material Weakness Repeat
  • 1225317 2025-002
    Material Weakness Repeat
  • 1225318 2025-002
    Material Weakness Repeat
  • 1225319 2025-002
    Material Weakness Repeat
  • 1225320 2025-002
    Material Weakness Repeat
  • 1225321 2025-002
    Material Weakness Repeat
  • 1225322 2025-002
    Material Weakness Repeat
  • 1225323 2025-002
    Material Weakness Repeat
  • 1225324 2025-002
    Material Weakness Repeat
  • 1225325 2025-002
    Material Weakness Repeat
  • 1225326 2025-002
    Material Weakness Repeat
  • 1225327 2025-002
    Material Weakness Repeat
  • 1225328 2025-002
    Material Weakness Repeat
  • 1225329 2025-002
    Material Weakness Repeat
  • 1225330 2025-002
    Material Weakness Repeat
  • 1225331 2025-002
    Material Weakness Repeat
  • 1225332 2025-002
    Material Weakness Repeat
  • 1225333 2025-002
    Material Weakness Repeat
  • 1225334 2025-002
    Material Weakness Repeat
  • 1225335 2025-002
    Material Weakness Repeat
  • 1225336 2025-002
    Material Weakness Repeat
  • 1225337 2025-002
    Material Weakness Repeat
  • 1225338 2025-002
    Material Weakness Repeat
  • 1225339 2025-002
    Material Weakness Repeat
  • 1225340 2025-002
    Material Weakness Repeat
  • 1225341 2025-002
    Material Weakness Repeat
  • 1225342 2025-002
    Material Weakness Repeat
  • 1225343 2025-002
    Material Weakness Repeat
  • 1225344 2025-002
    Material Weakness Repeat
  • 1225345 2025-002
    Material Weakness Repeat
  • 1225346 2025-002
    Material Weakness Repeat
  • 1225347 2025-002
    Material Weakness Repeat
  • 1225348 2025-002
    Material Weakness Repeat
  • 1225349 2025-002
    Material Weakness Repeat
  • 1225350 2025-003
    Material Weakness Repeat
  • 1225351 2025-003
    Material Weakness Repeat
  • 1225353 2025-004
    Material Weakness Repeat
  • 1225354 2025-004
    Material Weakness Repeat
  • 1225355 2025-004
    Material Weakness Repeat
  • 1225356 2025-004
    Material Weakness Repeat
  • 1225357 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.910 Federal Appropriations $153.23M
84.063 FEDERAL PELL GRANT PROGRAM $3.77M
84.910 Construction Fund Appropriations $2.29M
93.310 TRANS-NIH RESEARCH SUPPORT $973,688
93.110 SPECIAL PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $614,862
93.867 VISION RESEARCH $557,037
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $448,871
84.268 FEDERAL DIRECT STUDENT LOANS $436,564
93.433 ACL NATIONAL INSTITUTE ON DISABILITY, INDEPENDENT LIVING, AND REHABILITATION RESEARCH $226,702
84.160 TRAINING INTERPRETERS FOR INDIVIDUALS WHO ARE DEAF AND INDIVIDUALS WHO ARE DEAF-BLIND $149,486
98.001 USAID FOREIGN ASSISTANCE FOR PROGRAMS OVERSEAS $146,398
59.077 COMMUNITY NAVIGATOR PILOT PROGRAM $129,949
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $129,653
93.866 AGING RESEARCH $118,418
84.033 FEDERAL WORK-STUDY PROGRAM $115,970
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $107,748
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $91,147
93.879 MEDICAL LIBRARY ASSISTANCE $81,906
12.903 GENCYBER GRANTS PROGRAM $81,521
15.U01 Earthquake Science Center - Shake Alert $75,297
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $43,966
47.084 TECHNOLOGY, INNOVATION, AND PARTNERSHIPS $29,193
12.431 BASIC SCIENTIFIC RESEARCH $26,231
15.945 COOPERATIVE RESEARCH AND TRAINING PROGRAMS €“ RESOURCES OF THE NATIONAL PARK SYSTEM $24,714
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $24,402
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $24,207
93.173 RESEARCH RELATED TO DEAFNESS AND COMMUNICATION DISORDERS $23,517
45.162 PROMOTION OF THE HUMANITIES TEACHING AND LEARNING RESOURCES AND CURRICULUM DEVELOPMENT $20,646
93.U01 Improvements in Sign Language Detection for Videoconferencing $15,546
47.075 SOCIAL, BEHAVIORAL, AND ECONOMIC SCIENCES $13,649
93.U02 SBIR Phase II $1,723