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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.