Finding 1240281 (2025-014)

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

AI Summary

  • Core Issue: Inaccurate recipient counts for Pell Grants and other federal programs reported on the FISAP, violating federal requirements.
  • Impacted Requirements: Compliance with 34 CFR § 668.14 and § 690.83, which mandate accurate reporting of student financial aid data.
  • Recommended Follow-up: Enhance data validation and supervisory review processes to ensure accurate reporting and reconciliation of financial aid records.

Finding Text

Finding 2025-014 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Inaccurate Recipient Counts Reported on the FISAP (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 § 668.14 (b)(19) – Program Participation Agreement (PPA), institutions must accurately report to the Secretary information that the Secretary requires for participation in any Title IV, HEA program. Per 34 CFR § 690.83 (a), institutions must report annually to the Secretary the total number of students receiving Pell Grants and the distribution of those recipients by income category and ensure the report is complete and accurate. Inaccurate reporting violates federal reporting requirements and the institution’s Program Participation Agreement (PPA). Condition – During testing of the Fiscal Operations Report and Application to Participate (FISAP), we compared the number of recipients reported in selected income categories to the income information contained in the ISIRs reviewed. We found that the counts reported on the FISAP did not match the ISIR data, resulting in inaccurate reporting of Pell Grant recipients across certain income ranges. Cause – The inaccuracies appear to have resulted from failure to reconcile ISIR income information to the summary totals reported on the FISAP, use of incorrect or incomplete datasets when preparing recipient counts, and insufficient supervisory review over the FISAP reporting process. Effect - The Department of Education may receive incorrect statistical and demographic reporting used for policymaking and funding formulas, the institution is not in compliance with federal reporting requirements and its Program Participation Agreement, and there is also an increased risk of administrative capability concerns under 34 CFR § 668.16. Questioned Costs - $0 Repeat Finding - Yes Auditor’s Perspective – Accurate reporting of Pell Grant recipients by income category is essential because ED uses these data for national policy purposes, campus-based funding allocations, and program monitoring. Discrepancies between FISAP reported totals and ISIR data indicate a systemic reporting weakness, rather than a clerical oversight, and demonstrate the need for stronger data validation and reconciliation procedures. Auditor’s Recommendation - The University should strengthen review and approval controls and improve data validation processes by ensuring that datasets used for FISAP preparation are complete, consistent, and aligned with financial aid records. 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 2025-014 1. Finding Summary The auditor determined that the institution did not accurately report recipient counts for students receiving Pell Grants on the FISAP in accordance with federal reporting requirements. As a result, the institution could not demonstrate compliance with Title IV reporting obligations under its Program Participation Agreement, increasing the risk of inaccurate federal reporting and potential compliance findings. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that recipient counts reported on the FISAP were not consistently accurate in accordance with federal reporting requirements. 3. Root Cause Analysis The root cause of this finding resulted from failure to reconcile ISIR income data to the summary totals reported on the FISAP, use of incorrect or incomplete datasets when preparing recipient counts, and insufficient supervisory review of the FIS AP reporting process. 4. Corrective Action(s) Management has added secondary review, implemented periodic internal monitoring, and added system configuration limitations. Description of Corrective Actions The institution has implemented a supervisory or secondary review to validate FISAP data and recipient counts prior to submission, and established periodic internal monitoring and quality assurance reviews to ensure accuracy and completeness of reported information. Additionally, system configuration limitations impacting data extraction and reconciliation have been identified and addressed through revised reporting procedures and compensating manual controls. The next FISAP submission is due October 1, 2026. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions mitigate the risk of inaccurate FISAP reporting by strengthening oversight, improving data validation, and establishing compensating controls to address system limitations. Ongoing monitoring and quality assurance reviews further reduce compliance risk and support accurate and reliable federal reporting. 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: D Yes 18N1 o • If not fully implemented, expected completion date: December 31, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) D Fully implemented D Partially implemented 181N ot yet implemented Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability Supervisory review and periodic internal monitoring will be conducted each reporting cycle to ensure FISAP recipient counts are accurate, complete, and supported by reconciled data. Continued use of quality assurance reviews, documented procedures, and compensating controls for system limitations will support long-term compliance and timely identification and correction of reporting discrepancies.

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
  • 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
  • 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
  • 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