Finding 1240269 (2025-011)

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

AI Summary

  • Core Issue: The University disbursed Title IV funds to students without obtaining required verification documentation, violating federal regulations.
  • Impacted Requirements: Compliance with 34 CFR § 668.53(a)(3) and § 668.56, which mandate verification before disbursement, was not met.
  • Recommended Follow-Up: Implement a verification checklist, enhance internal controls, and conduct regular audits of student files to ensure compliance.

Finding Text

Finding 2025-011 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Failure to Obtain Required Verification Documentation Prior to Disbursing Title IV Aid (Significant Deficiency): 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 § 668.53(a)(3) and 34 CFR § 668.56, when a student is selected for verification, the institution must collect and review the required verification documentation before disbursing Title IV funds, unless the student qualifies for a permitted interim disbursement or other regulatory exception. Additionally, under 34 CFR § 668.16(f), the institution must develop and apply an adequate system to identify and resolve discrepancies in information that would affect a student’s Title IV eligibility. Condition – During testing of sixty (60) students, seven (7) students were identified as having been selected for verification. Of the seven (7) students subject to verification, two (2) students did not have the required verification documentation in the student file; however, Title IV funds were disbursed on the students’ behalf. As a result, the University disbursed Title IV funds without documentation demonstrating that the students’ eligibility had been verified in accordance with federal requirements. Cause – The exceptions appear to have occurred due to breakdowns in the verification tracking process and insufficient review procedures to prevent packaging and disbursement prior to completing verification. Effect – As a result, the University awarded and disbursed Title IV funds to students whose eligibility was not properly verified. This creates a risk of improper payment and may result in questioned costs for the Title IV funds disbursed to students. Questioned Costs – $5,546 Repeat Finding – Yes Auditor’s Perspective – Verification is a key Title IV eligibility control designed to ensure that federal aid is awarded based on accurate and supported student information. In this instance, two (2) out of seven (7) students selected for verification (28.57%), or two (2) out of sixty (60) students tested overall (3.33%), did not have the required documentation on file prior to disbursement. The absence of the required documentation prevents the University from demonstrating that verification was properly completed and that the students’ eligibility for Title IV funds was adequately supported prior to disbursement. The 28.57% exception rate among students subject to verification indicates a weakness in the University’s controls over the verification process and its maintenance of documentation necessary to substantiate compliance with Title IV requirements. Auditor’s Recommendation – The University should implement a verification checklist and tracking system, strengthen internal controls, and perform periodic file audits. 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 2025-011 1. Finding Summary The auditor determined that the institution did not consistently obtain and document required verification information prior to disbursing Title IV federal student aid for students selected for verification. As a result, the institution could not demonstrate compliance with federal verification requirements, increasing the risk that Title IV funds were disbursed before verification was completed. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that required verification documentation was not consistently obtained and documented prior to the disbursement of Title IV federal student aid for students selected for verification. 3. Root Cause Analysis The root cause of this finding resulted from weaknesses in verification monitoring procedures and inadequate review controls, which allowed Title IV aid to be packaged and disbursed prior to the completion and documentation of required verification. 4. Corrective Action(s) Management has implemented standardized checklists and workflows, added secondary review, provided additional training to staff, and implemented periodic internal monitoring. Description of Corrective Actions Management has implemented enhanced verification workflows and system controls to prevent packaging or disbursement of Title IV aid until verification is fully completed. A mandatory supervisory review has been established, and targeted staff training has been conducted to reinforce verification requirements. Periodic internal monitoring and quality assurance reviews will be performed to ensure ongoing compliance. 5. Risk Mitigation (Required - Even if Disagreeing) The corrective actions mitigate the risk of disbursing Title IV funds prior to verification completion by strengthening verification workflows, system controls, and supervisory review. Targeted staff training and ongoing internal monitoring further reduce the likelihood of premature disbursements and support sustained compliance with federal verification requirements. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Director of Financial Aid • Name (optional): ____________ _ 7. Implementation Timeline • Corrective action implemented: ~ Yes D No • If not fully implemented, expected completion date: 8. Status of Corrective Action (For Prior-Year or Repeat Findings) ~ Fully implemented D Partially implemented D Not yet implemented Evidence of Implementation Evidence of verifications completed in May through July 2026. 9. Monitoring and Sustainability Management will conduct regular supervisory and periodic internal reviews of verification files to confirm that required documentation is completed prior to Title IV packaging and disbursement. Continued staff training, maintained system controls, and standardized verification procedures will be sustained to ensure long-term compliance and timely identification of any deficiencies.

Categories

Student Financial Aid Eligibility Significant Deficiency

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
  • 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
  • 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