Finding 1227343 (2025-007)

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

AI Summary

  • Core Issue: The University drew down federal Student Financial Assistance funds beyond immediate disbursement needs, violating federal cash management regulations.
  • Impacted Requirements: Federal regulations mandate that institutions must minimize the time between fund drawdowns and disbursement, ensuring funds are not drawn in excess of immediate needs.
  • Recommended Follow-Up: The University should assess and improve its monitoring controls to ensure compliance with cash management requirements and timely reconciliations across all programs.

Finding Text

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.063, 84.268 Federal Agency: Department of Education (DOE) Federal Award Numbers: P007A243392, P063P242023, P268K252023; Award Year: 2025 Criteria: Federal regulations require institutions to minimize the time between the drawdown of federal funds and their disbursement to students, and to ensure that drawdowns do not exceed immediate cash needs. Institutions must maintain adequate internal controls to ensure federal funds are not drawn in excess of amounts needed for disbursement. Condition: During testing, it was noted that the University drew down Student Financial Assistance funds in excess of immediate disbursement needs at various points throughout the year. Specifically: • Pell Grant funds of up to $35,531 at different points of the year were drawn but not disbursed within the required timeframe. Funds totaling $4,224 remained overdrawn as of June 30, 2025. • SEOG funds of up to $120,508 at different points of the year were drawn but not disbursed within the required timeframe. Funds totaling $120,508 remained overdrawn as of June 30, 2025. • Federal Direct Loans of up to $351,211 at different points of the year were drawn but not disbursed within the required timeframe. Funds totaling $73,597 remained overdrawn as of June 30, 2025. Cause: The University did not have adequate monitoring controls in place to ensure that drawdowns were limited to immediate cash needs and that fund balances were reconciled timely and accurately across programs. Testing indicated reconciliations were not routinely performed between the University's systems and federal systems, resulting in these errors. Effect: The University was not in compliance with federal cash management requirements, as federal funds were drawn in excess of allowable amounts. This increases the risk of improper cash management and potential noncompliance with Department of Education regulations. Questioned Costs: None reported Context: Testing identified multiple instances of overdrawn fund positions across the SEOG, Federal Direct Loan, and Pell programs throughout the fiscal year, occurring at various points in time and in varying amounts. Overdrawn conditions were not isolated to a single period or program but were observed intermittently across all three programs. At fiscal year-end, two of the three programs tested (SEOG and Federal Direct Loan) remained in an overdrawn position, while the Pell program was resolved prior to year-end. Repeat Finding: Yes Recommendations: We recommend that the University evaluate its processes and controls to ensure cash draws are completed for appropriate amounts. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.

Corrective Action Plan

Federal Direct Loan FY24-25: Award # P268K252023 Pell Grant FY24-25: Award # P063P242023 SEOG FY24-25: Award # P007A243392 Condition Summary: SEOG, Federal Direct Loan, and Pell funds were drawn down in excess of immediate disbursement needs at various points during the year, and SEOG and Federal Direct Loan remained in an overdrawn position at year-end. Management Response / Corrective Action Plan: Management concurs with this finding. The lack of routine reconciliation between the University's internal systems and federal drawdown systems allowed overdrawn positions to persist. The University's full review of 2025-2026 activity included reconstructing drawdown history and bringing all programs current. Going forward, the consulting firm engaged by the University is performing a documented reconciliation between institutional records and G5 drawdown activity on no less than a bi-weekly basis, with any variance requiring same-week resolution. Personnel who previously held responsibility for cash management are no longer employed at the institution. Responsible Party - Michael DeWees, Vice President for Finance and Administration, Controller (Vacant) & Raymond Nault, Interim Director of Student Financial Services 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

Cash Management Student Financial Aid

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
  • 1227342 2025-006
    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