Finding 1227324 (2025-009)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
-
Year
2025
Accepted
2026-08-19
Audit: 409430
Organization: Wittenberg University (OH)
Auditor: RSM US LLP

AI Summary

  • Core Issue: The institution failed to maintain required Perkins loan documentation, including signed promissory notes and adequate repayment records.
  • Impacted Requirements: Noncompliance with 34 CFR §674.19(e) regarding documentation retention for federal student loans.
  • Recommended Follow-Up: Evaluate and improve processes and controls to ensure proper maintenance of Perkins loan documentation.

Finding Text

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.038 Federal Agency: Department of Education (DOE) Federal Award Numbers: Unknown; Award Year: 2025 Criteria: Per 34 CFR §674.19(e), institutions participating in the Federal Perkins Loan Program are required to maintain loan documentation, including properly executed promissory notes and repayment records, for each loan. Such records must be retained until the loan is satisfied, assigned to the U.S. Department of Education, or otherwise resolved, with certain repayment documentation retained for a minimum period following loan resolution. Condition: During prior year testing of Perkins loan documentation, the following exceptions were identified from a sample of 25 loans: 1. 3 of 25 loans did not have a signed promissory note on file. 2. 24 of 25 loans did not have adequate repayment documentation maintained. Due to the nature of the requirement and the extended document retention period, the conditions noted above continue to represent noncompliance with federal requirements. Cause: Turnover within the financial aid and related administrative departments resulted in a lack of continuity in maintaining Perkins loan documentation. Effect: The absence of promissory notes and repayment documentation increases the risk that the institution cannot support loan balances, enforce repayment in the event of default, or demonstrate compliance with federal program requirements. This may result in potential liability, including required assignment of loans to the U.S. Department of Education. Questioned Costs: None reported Context: The prior year exceptions reflect deficiencies in maintaining required Perkins loan documentation across a significant portion of the population tested. Due to the long-term retention requirements associated with Perkins loans, these deficiencies remain relevant in the current year. Repeat Finding: Yes Recommendations: We recommend that the University evaluate its processes and controls to ensure Perkins loan documentation is maintained according to requirements. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.

Corrective Action Plan

Condition Summary: 3 of 25 loans tested lacked a signed promissory note, and 24 of 25 loans lacked adequate repayment documentation. Management Response / Corrective Action Plan: Management concurs with this finding. The University has directed the engaged consulting firm to complete a full inventory of the remaining Perkins Loan portfolio, working with the loan servicer to reconstruct or obtain missing promissory notes and repayment records wherever possible, and to document the resolution status of each loan file. Administrative staff previously responsible for maintaining this documentation are no longer employed at the institution. Because the Perkins Loan program is in wind-down status and documentation gaps largely predate the current administration, full file reconstruction may extend beyond the current award year; the University will report progress to the Department of Education as file remediation continues. Responsible Party - Ebony Martin, Associate Director of Student Accounts Title - Interim oversight: Engaged Consulting Firm Anticipated Completion Date - August 24, 2026 Note: Because the corrective actions described above were substantially implemented during and after the fiscal year 2025 audit period, management anticipates that this condition, or elements of it, may continue to be identified as a finding in the University's fiscal year 2025-2026 single audit. Full operating effectiveness of the revised controls will not be demonstrable until they have been in place for a complete testing cycle.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1227309 2025-004
    Material Weakness Repeat
  • 1227310 2025-005
    Material Weakness Repeat
  • 1227311 2025-006
    Material Weakness Repeat
  • 1227312 2025-007
    Material Weakness Repeat
  • 1227313 2025-008
    Material Weakness Repeat
  • 1227314 2025-010
    Material Weakness Repeat
  • 1227315 2025-012
    Material Weakness Repeat
  • 1227316 2025-013
    Material Weakness Repeat
  • 1227317 2025-005
    Material Weakness Repeat
  • 1227318 2025-006
    Material Weakness Repeat
  • 1227319 2025-010
    Material Weakness Repeat
  • 1227320 2025-012
    Material Weakness Repeat
  • 1227321 2025-013
    Material Weakness Repeat
  • 1227322 2025-005
    Material Weakness Repeat
  • 1227323 2025-006
    Material Weakness Repeat
  • 1227325 2025-010
    Material Weakness Repeat
  • 1227326 2025-012
    Material Weakness Repeat
  • 1227327 2025-013
    Material Weakness Repeat
  • 1227328 2025-005
    Material Weakness Repeat
  • 1227329 2025-006
    Material Weakness Repeat
  • 1227330 2025-007
    Material Weakness Repeat
  • 1227331 2025-010
    Material Weakness Repeat
  • 1227332 2025-011
    Material Weakness Repeat
  • 1227333 2025-012
    Material Weakness Repeat
  • 1227334 2025-013
    Material Weakness Repeat
  • 1227335 2025-005
    Material Weakness Repeat
  • 1227336 2025-006
    Material Weakness Repeat
  • 1227337 2025-010
    Material Weakness Repeat
  • 1227338 2025-012
    Material Weakness Repeat
  • 1227339 2025-013
    Material Weakness Repeat
  • 1227340 2025-004
    Material Weakness Repeat
  • 1227341 2025-005
    Material Weakness Repeat
  • 1227342 2025-006
    Material Weakness Repeat
  • 1227343 2025-007
    Material Weakness Repeat
  • 1227344 2025-008
    Material Weakness Repeat
  • 1227345 2025-010
    Material Weakness Repeat
  • 1227346 2025-012
    Material Weakness Repeat
  • 1227347 2025-013
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $8.42M
84.063 FEDERAL PELL GRANT PROGRAM $2.73M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $1.52M
84.047 TRIO UPWARD BOUND $371,444
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $246,539
84.033 FEDERAL WORK-STUDY PROGRAM $197,921
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $125,283
45.162 PROMOTION OF THE HUMANITIES TEACHING AND LEARNING RESOURCES AND CURRICULUM DEVELOPMENT $30,978
84.021 OVERSEAS PROGRAMS - GROUP PROJECTS ABROAD $12,176
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $11,208
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $9,503
81.049 OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM $3,956
43.001 SCIENCE $3,045