Finding 1227346 (2025-012)

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 institution failed to perform required verification procedures for 2 out of 3 students selected for verification, lacking necessary documentation and oversight.
  • Impacted Requirements: This noncompliance with federal regulations (34 CFR 668.51–668.60) increases the risk of disbursing Title IV funds based on inaccurate information.
  • Recommended Follow-Up: The University should assess and improve its verification processes and controls to ensure all required procedures are completed and documented effectively.

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: Institutions are required to perform verification procedures for students selected for verification by the U.S. Department of Education (ED), including obtaining required documentation, comparing the information to the student’s FAFSA data, making necessary corrections, and updating verification status, in accordance with 34 CFR 668.51–668.60 and the OMB Compliance Supplement. Condition: During testing of students selected for verification, we noted that 2 of 3 students tested did not have evidence that required verification procedures were performed. Specifically, the institution did not obtain or document supporting verification information or complete required comparison and correction procedures for this student. Additionally, controls to track verification processes were being completed timely and accurately were not operating during the academic year. The sample was not intended to be, and was not, a statistically valid sample. Cause: The condition is attributable to turnover within the Student Financial Assistance office during the year, which resulted in gaps in personnel responsible for performing and monitoring verification procedures. As a result, the institution did not maintain effective oversight or continuity in its verification processes to ensure that all students selected for verification had required procedures completed and documented. Effect: Failure to perform required verification procedures may result in the disbursement of Title IV funds based on inaccurate or unverified student information, increasing the risk of improper payments and noncompliance with federal requirements. Questioned Costs: None reported Context: Failure to perform verification procedures for students selected by the U.S. Department of Education represents noncompliance within the “Special Tests and Provisions—Verification” compliance requirement and increases the risk that aid may be awarded based on incomplete or inaccurate information. Repeat Finding: No Recommendations: We recommend that the University evaluate its processes and controls to ensure verifications are properly performed and documented. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.

Corrective Action Plan

Condition Summary: 2 of 3 students selected for verification lacked evidence that required verification procedures were performed, and controls to track verification completion were not operating during the academic year. Management Response / Corrective Action Plan: Management concurs with this finding. The University has directed the engaged consulting firm to complete a full review of 2025-2026 verification activity, obtain and document outstanding verification records, and complete any required corrections to FAFSA data. A dedicated verification tracking log, maintained by the consulting firm, now records each selected student's status from selection through completion. Staff previously responsible for monitoring verification completion are no longer employed at the institution. Responsible Party - 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

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring 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
  • 1227342 2025-006
    Material Weakness Repeat
  • 1227343 2025-007
    Material Weakness Repeat
  • 1227344 2025-008
    Material Weakness Repeat
  • 1227345 2025-010
    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