Finding 1240249 (2025-006)

Material Weakness Repeat Finding
Requirement
CELN
Questioned Costs
-
Year
2025
Accepted
2026-10-10

AI Summary

  • Core Issue: The University failed to reconcile Title IV financial aid programs, leading to discrepancies in disbursement records.
  • Impacted Requirements: Non-compliance with 34 CFR § 668.24 and Federal Student Aid Handbook, risking regulatory scrutiny and financial inaccuracies.
  • Recommended Follow-Up: Implement monthly reconciliations, enhance coordination between departments, and conduct year-end reconciliations before FISAP submission.

Finding Text

Finding 2025-006 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Failure to Reconcile Title IV Programs (Material Weakness): Information on the federal program – Federal Direct Student Loans, ALN 84.268, June 30, 2025; Federal Pell Grant Program, ALN 84.063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, ALN 84.007, June 30, 2025; Federal Work-Study Program, ALN 84.033, June 30, 2025. Criteria – Per 34 CFR § 668.24 (a), institutions must maintain records necessary to demonstrate compliance with the requirements of Title IV of the Higher Education Act (HEA) programs, including records that support the accuracy of disbursements and fiscal transactions. Per the Federal Student Aid Handbook, Volume 4 – Processing Aid and Managing Funds, institutions are required to reconcile internal disbursement and expenditure records with the Business Office, general ledger, and the Department of Education’s systems (COD, G5, etc.) on a monthly basis for all Title IV programs. Additionally, for Federal Direct Loans specifically, per 34 CFR § 685.300(b)(5), institutions must reconcile the institution’s Federal Direct Loan records with the Department’s records at least monthly and resolve any discrepancies. Condition – The University did not perform required reconciliations between the Office of Financial Aid and the Business Office for the following Title IV programs during the audit period: • Federal Pell Grant Program • Federal Direct Student Loans • Federal Supplemental Educational Opportunity Grant (FSEOG) • Federal Work-Study (FWS) Program As a result, disbursement records maintained by the Office of Financial Aid did not reconcile to the general ledger or COD for any of the programs reviewed. No documentation of monthly or year-end reconciliations was provided for audit examination. Cause – The lack of reconciliation appears to have resulted from insufficient coordination and reconciliation timeliness between the Office of Financial Aid and the Business Office Effect – Failure to reconcile may impact the University’s administrative capability under 34 CFR § 668.16, exposing the University to regulatory review, questioned costs, and potential repayment liability. There is also an increased risk of overpayments or underpayments of federal aid and misstatements in the Schedule of Expenditures of Federal Awards (SEFA) and general ledger. Questioned Costs – $0 Repeat Finding – Yes Auditor’s Perspective – Reconciliation is a foundational internal control for Title IV program administration. The failure to reconcile across all four major programs indicates a systemic, not isolated, weakness in financial aid and accounting oversight. Auditor’s Recommendation – The University should implement monthly reconciliations, strengthen cross-department coordination, and perform year-end reconciliation prior to FISAP submission. Implementation of these measures will help ensure compliance with federal regulations, reduce financial reporting risk, and reinforce the University’s administrative capability. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.

Corrective Action Plan

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2025-006 1. Finding Summary The auditor found that the University did not complete or document required monthly or year-end reconciliations for several Title IV programs, resulting in unreconciled financial aid records between the Office of Financial Aid, the general ledger, and federal systems. Federal regulations require these reconciliations to ensure the accuracy of disbursements and compliance with Title IV requirements. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges the failure to perform timely and documented reconciliations of Title IV programs during the audit period. Management concurs with the auditor's assessment that reconciliation is a critical internal control and recognizes the need to strengthen coordination, documentation, and timeliness between the Office of Financial Aid and the Business Office. 3. Root Cause Analysis The root cause was insufficient staff training on Title IV reconciliation and reporting requirements, resulting in inconsistent understanding of regulatory timelines, documentation standards, and cross-department coordination responsibilities. These training gaps limited the effective implementation of required reconciliation and monitoring processes. 4. Corrective Action(s) Management is working to implement standardized workflows and periodic internal monitoring between the Office of Financial Aid and the Business Office. Description of Corrective Actions To address this finding and prevent recurrence, the University has implemented standardized reconciliation procedures aligned with federal requirements. Reconciliation responsibilities have been formally assigned to a designated Financial Aid Counselor, with monthly reconciliations scheduled throughout each month for all Title IV programs. The Office of Financial Aid now utilizes standardized reconciliation checklists and templates, requires documented coordination and data matching with the Business Office and federal systems (COD and GS), and retains all monthly and year-end reconciliation records in accordance with federal record-keeping requirements. In addition, a mandatory year-end reconciliation review is completed prior to FISAP submission to ensure consistency across internal records, the general ledger, and federal reporting systems. The University is slightly behind on monthly reconciliations, but is working to complete July 2026 and August 2026 reconcilations and to revise the progress to shorten the time required to complete reconciliations. 5. Risk Mitigation (Required - Even if Disagreeing) The University acknowledges the need to proactively manage regulatory exposure in this area. The corrective measures implemented are intended to strengthen oversight, promote consistent application of federal requirements, improve the accuracy and timeliness of reconciliation activities, and minimize the likelihood of future reporting issues or audit observations. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Financial Aid Director •Name (optional): 7. Implementation Timeline • Corrective action implemented: ~ Yes D No • If not fully implemented, expected completion date: December 31, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) D Fully implemented ~ Partially implemented D Not yet implemented Evidence of Implementation Monthly reconciliations and close-outs of prior year aid periods. 9. Monitoring and Sustainability The University will maintain ongoing oversight of reconciliation activities through routine internal reviews and supervisory verification to ensure procedures are consistently followed. Reconciliation processes and documentation practices will be periodically evaluated and updated as needed to support sustained compliance with Title IV requirements and long-term operational effectiveness.

Categories

Student Financial Aid Reporting

Other Findings in this Audit

  • 1240228 2025-003
    Material Weakness Repeat
  • 1240229 2025-003
    Material Weakness Repeat
  • 1240230 2025-003
    Material Weakness Repeat
  • 1240231 2025-003
    Material Weakness Repeat
  • 1240232 2025-003
    Material Weakness Repeat
  • 1240233 2025-003
    Material Weakness Repeat
  • 1240234 2025-003
    Material Weakness Repeat
  • 1240235 2025-003
    Material Weakness Repeat
  • 1240236 2025-003
    Material Weakness Repeat
  • 1240237 2025-003
    Material Weakness Repeat
  • 1240238 2025-003
    Material Weakness Repeat
  • 1240239 2025-003
    Material Weakness Repeat
  • 1240240 2025-003
    Material Weakness Repeat
  • 1240241 2025-003
    Material Weakness Repeat
  • 1240242 2025-003
    Material Weakness Repeat
  • 1240243 2025-003
    Material Weakness Repeat
  • 1240244 2025-004
    Material Weakness Repeat
  • 1240245 2025-005
    Material Weakness Repeat
  • 1240246 2025-006
    Material Weakness Repeat
  • 1240247 2025-006
    Material Weakness Repeat
  • 1240248 2025-006
    Material Weakness Repeat
  • 1240250 2025-007
    Material Weakness Repeat
  • 1240251 2025-007
    Material Weakness Repeat
  • 1240252 2025-007
    Material Weakness Repeat
  • 1240253 2025-007
    Material Weakness Repeat
  • 1240254 2025-008
    Material Weakness Repeat
  • 1240255 2025-008
    Material Weakness Repeat
  • 1240256 2025-008
    Material Weakness Repeat
  • 1240257 2025-008
    Material Weakness Repeat
  • 1240258 2025-009
    Material Weakness Repeat
  • 1240259 2025-009
    Material Weakness Repeat
  • 1240260 2025-009
    Material Weakness Repeat
  • 1240261 2025-009
    Material Weakness Repeat
  • 1240262 2025-010
    Material Weakness Repeat
  • 1240263 2025-010
    Material Weakness Repeat
  • 1240264 2025-010
    Material Weakness Repeat
  • 1240265 2025-010
    Material Weakness Repeat
  • 1240266 2025-011
    Material Weakness Repeat
  • 1240267 2025-011
    Material Weakness Repeat
  • 1240268 2025-011
    Material Weakness Repeat
  • 1240269 2025-011
    Material Weakness Repeat
  • 1240270 2025-012
    Material Weakness Repeat
  • 1240271 2025-012
    Material Weakness Repeat
  • 1240272 2025-012
    Material Weakness Repeat
  • 1240273 2025-012
    Material Weakness Repeat
  • 1240274 2025-013
    Material Weakness Repeat
  • 1240275 2025-013
    Material Weakness Repeat
  • 1240276 2025-013
    Material Weakness Repeat
  • 1240277 2025-013
    Material Weakness Repeat
  • 1240278 2025-014
    Material Weakness Repeat
  • 1240279 2025-014
    Material Weakness Repeat
  • 1240280 2025-014
    Material Weakness Repeat
  • 1240281 2025-014
    Material Weakness Repeat
  • 1240282 2025-015
    Material Weakness Repeat
  • 1240283 2025-015
    Material Weakness Repeat
  • 1240284 2025-015
    Material Weakness Repeat
  • 1240285 2025-015
    Material Weakness Repeat
  • 1240286 2025-016
    Material Weakness Repeat
  • 1240287 2025-016
    Material Weakness Repeat
  • 1240288 2025-016
    Material Weakness Repeat
  • 1240289 2025-016
    Material Weakness Repeat
  • 1240290 2025-017
    Material Weakness Repeat
  • 1240291 2025-017
    Material Weakness Repeat
  • 1240292 2025-017
    Material Weakness Repeat
  • 1240293 2025-017
    Material Weakness Repeat
  • 1240294 2025-018
    Material Weakness Repeat
  • 1240295 2025-018
    Material Weakness Repeat
  • 1240296 2025-018
    Material Weakness Repeat
  • 1240297 2025-018
    Material Weakness Repeat
  • 1240298 2025-019
    Material Weakness Repeat
  • 1240299 2025-019
    Material Weakness Repeat
  • 1240300 2025-019
    Material Weakness Repeat
  • 1240301 2025-019
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $4.67M
84.063 FEDERAL PELL GRANT PROGRAM $3.57M
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $566,939
84.031 HIGHER EDUCATION_INSTITUTIONAL AID $445,997
93.658 FOSTER CARE_TITLE IV-E $212,366
84.033 FEDERAL WORK-STUDY PROGRAM $88,615
47.076 EDUCATION AND HUMAN RESOURCES $65,481
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $37,012
93.307 MINORITY HEALTH AND HEALTH DISPARITIES RESEARCH $14,994
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $11,071
47.083 INTEGRATIVE ACTIVITIES $4,382