Finding 1227342 (2025-006)

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

AI Summary

  • Core Issue: The University failed to process 5 out of 40 student credit balance refunds within the required 14-day period, lacking proper controls for review and approval.
  • Impacted Requirements: Noncompliance with federal regulations for Title IV refunds and inadequate financial record-keeping for federal assistance transactions.
  • Recommended Follow-Up: Implement robust processes and controls to ensure timely identification and processing of federal aid credit balances.

Finding Text

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.038, 84.007, 84.268, 84.379 Federal Agency: Department of Education (DOE) Federal Award Numbers: P063P242023, P033A243392, Unknown, P007A243392, P268K252023, P379T0972023; Award Year: 2025 Criteria: Federal regulations require institutions to pay Title IV credit balance refunds to students or parents as soon as possible, but no later than 14 days after the credit balance occurs. In addition, institutions must establish and maintain on a current basis, financial records that reflect each Title IV program transaction; and general ledger control accounts and related subsidiary accounts that identify each Title IV program transaction and separate those transactions from all other institutional financial activity in accordance with 34 C.F.R, 668.24(b)(2). Condition: During our review, we identified 5 of 40 student credit balance refunds that were processed outside of the required 14-day timeframe. Controls for proper review and approval of these refunds were not in place during the entire year under audit. In addition, the University was unable to produce a report to specifically identify which credit balances were attributable to federal financial assistance, as opposed to institutional, state, or other non-federal sources. The sample was not intended to be, and was not, a statistically valid sample. Cause: The institution did not have adequate internal controls or monitoring procedures in place to ensure compliance with credit balance requirements Effect: The University did not fully comply with federal Title IV requirements. Failure to timely process credit balance refunds and to properly identify federal aid credit balances increases the risk of noncompliance, potential regulatory findings, and possible enforcement actions by the U.S. Department of Education. Questioned Costs: None reported Context: Controls did not operate properly for the University to comply with requirements for disbursements to and on behalf of students. Repeat Finding: Yes Recommendations: We recommend that the University implement proper processes and controls to ensure all credit balances resulting from federal aid are properly identified and returned timely. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.

Corrective Action Plan

Condition Summary: 5 of 40 credit balance refunds were processed outside the required 14-day timeframe, controls over review and approval were not operating for the full year, and the University could not produce a report distinguishing Title IV credit balances from other funding sources. Management Response / Corrective Action Plan: Management concurs with this finding. As part of the University's full review of 2025-2026 cash management activity, a revised credit-balance workflow has been established requiring supervisory approval and a system-generated report that separately identifies balances attributable to Title IV funds. Staff associated with the prior lapse in controls are no longer employed at the institution, and the engaged consulting firm is providing interim monitoring of the 14-day refund requirement, with weekly exception reporting until the control is demonstrated to be operating effectively on a sustained basis. 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 Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

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
  • 1227324 2025-009
    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
  • 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