Finding 1240253 (2025-007)

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

AI Summary

  • Core Issue: The Office of Financial Aid reported unreconciled expenditures in the FISAP, leading to discrepancies with federal systems.
  • Impacted Requirements: Non-compliance with 34 CFR § 668.24 and the Federal Student Aid Handbook, risking the institution's administrative capability.
  • Recommended Follow-Up: Implement monthly reconciliations, enhance coordination between departments, and ensure year-end reconciliations are completed before FISAP submission.

Finding Text

Finding 2025-007 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Unreconciled Expenditures Reported on the FISAP (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 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 on a monthly basis for all Title IV programs prior to completing year-end federal reporting including the FISAP. Condition – The Office of Financial Aid submitted unreconciled expenditure amounts in the institution’s Fiscal Operations Report and Application to Participate (FISAP). At the time of audit, the reported FISAP totals did not reconcile to the applicable federal systems (COD) or to the Student Financial Aid (SFA) reconciliation report. No documentation was provided to demonstrate that final reconciliations were completed prior to submission of the FISAP. 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 institution’s administrative capability under 34 CFR § 668.16, exposing the University to regulatory review, questioned costs, and potential repayment liability. The accuracy and reliability of the FISAP submission cannot be assured. Questioned Costs – $0 Repeat Finding - Yes Auditor’s Perspective – The FISAP serves as a primary financial reporting tool used by the Department of Education to determine campus-based program funding and institutional compliance. Submitting unreconciled figures undermines the integrity of federal reporting and represents a systemic breakdown in financial oversight rather than an isolated reporting error. Auditor’s Perspective – (continued) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations Report and Application to Participate (FISAP) for the programs below: a. Federal Pell Grant Program b. Federal Work Study (FWS) Program c. Federal Supplemental Educational Opportunity Grant (FSEOG) Auditor’s Recommendation – The University should implement monthly reconciliations, strengthen cross-department coordination, perform year-end reconciliation prior to FISAP submission. Implementation of these measures will strengthen financial accountability, improve federal reporting accuracy, and reduce the likelihood of future findings. 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 2025-007 1. Finding Summary The auditor found that the University submitted unreconciled expenditure data on the FISAP for the Federal Pell Grant, Federal Work-Study, and Supplemental Educational Opportunity Grant programs, with reported amounts not aligning to internal records, the general ledger, or federal systems. This condition reflects weaknesses in reconciliation timeliness and oversight and increases the risk of inaccurate federal reporting. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges the submission of unreconciled expenditure data within the Fiscal Operations Report and Application to Participate (FISAP). Management concurs that all Title IV expenditures must be fully reconciled to internal records, federal systems, and the general ledger prior to year-end federal reporting to ensure accuracy and compliance with federal requirements. 3. Root Cause Analysis Office of Fiscal Affairs The root cause was a combination of insufficient supervisory review and training gaps related to Title IV reconciliation and FISAP reporting requirements. These conditions resulted in delays in completing final reconciliations, inconsistent coordination between the Office of Financial Aid and the Business Office, and the submission of federal reports without documented confirmation that expenditures reconciled to internal records and federal systems. 4. Corrective Action(s) Management is working to implement standardized workflows and periodic internal monitoring. Description of Corrective Actions To address this finding and prevent recurrence, the University has strengthened its reconciliation and reporting processes by implementing mandatory monthly reconciliations for all Title IV programs and requiring completion of a documented year-end reconciliation prior to submission of the FISAP. The Office of Financial Aid now utilizes standardized reconciliation templates and documentation procedures and coordinates closely with the Business Office to ensure reported expenditures reconcile to internal records, the general ledger, and federal systems. In addition, supervisory review has been incorporated into the reconciliation and FISAP preparation process to verify accuracy, resolve discrepancies timely, and ensure federal reporting is complete, accurate, and supported by reconciliation documentation. The next FISAP submission is due October 1, 2026. 5. Risk Mitigation (Required - Even if Disagreeing) The University recognizes the importance of reducing exposure related to federal reporting accuracy and compliance. The corrective actions implemented are intended to strengthen oversight of reconciliation and FISAP reporting, improve coordination between responsible offices, and ensure that reported expenditure data is supported by timely and documented reconciliations, thereby reducing the likelihood of inaccurate reporting or future audit findings. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Financial Aid Director • Name (optional): ____________ _. 7. Implementation Timeline • Corrective action implemented: D Yes C8l No • If not fully implemented, expected completion date: October 1, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) D Fully implemented D Partially implemented x Not yet implemented Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability The University will monitor compliance through ongoing supervisory review of monthly and yearend reconciliation documentation and periodic internal reviews of FISAP preparation processes. Reconciliation procedures and reporting controls will be routinely evaluated and reinforced through staff training and management oversight to support sustained compliance and accurate federal reporting.

Categories

Student Financial Aid

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
  • 1240249 2025-006
    Material Weakness Repeat
  • 1240250 2025-007
    Material Weakness Repeat
  • 1240251 2025-007
    Material Weakness Repeat
  • 1240252 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