Finding 1240293 (2025-017)

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

AI Summary

  • Core Issue: A student was under-awarded Federal Pell Grant funds due to insufficient controls over eligibility calculations and disbursement processes.
  • Impacted Requirements: Compliance with 34 CFR § 690.62 and § 668.24 regarding accurate determination and disbursement of Federal Pell Grant amounts.
  • Recommended Follow-Up: Review the student's eligibility, make necessary disbursements, strengthen calculation procedures, and reconcile discrepancies with COD.

Finding Text

Finding 2025-017 – U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Federal Pell Grant Under Awarded (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 – In accordance with 34 CFR § 690.62, institutions participating in the Federal Pell Grant Program are responsible for determining and disbursing the appropriate Federal Pell Grant amount for each eligible student based on the student's applicable Scheduled Federal Pell Grant Award and enrollment intensity for the payment period. Additionally, 34 CFR § 668.24 requires institutions to establish and maintain records sufficient to demonstrate the proper administration of Title IV programs and to support the eligibility and amounts of Title IV assistance awarded and disbursed. Federal Pell Grant payments must be calculated in accordance with applicable Federal Pell Grant payment requirements, including the student's enrollment intensity and eligibility for each payment period. Eligible students may also receive additional Federal Pell Grant funds under the Year- Round Pell provisions, subject to applicable eligibility requirements and the statutory maximum of 150 percent of the student's Scheduled Federal Pell Grant Award for the award year. Condition – During testing of Federal Pell Grant eligibility and disbursements, we noted that one student was not awarded the full amount of Federal Pell Grant funds for which the student was eligible during the 2024–2025 award year. The student was enrolled during the Fall, Spring, and summer payment periods and was eligible for Federal Pell Grant funds based on the student's applicable Pell Grant eligibility and enrollment intensity. However, the institution disbursed less Federal Pell Grant assistance than the amount for which the student was eligible. Additionally, the student's institutional account reflected $4,622, while the COD Pell SAS Report reflected $6,019, resulting in an unreconciled difference of $1,397. Cause – The exception appears to have resulted from insufficient controls over the calculation, awarding, and reconciliation of Federal Pell Grant funds, including procedures to ensure that Pell eligibility is appropriately calculated for each payment period and that the University’s disbursement records agree with amounts reported to COD. Effect – Failure to accurately calculate and disburse Federal Pell Grant eligibility resulted in the student receiving less Federal Pell Grant assistance than the amount for which the student was eligible. Additionally, the unreconciled difference between the institution's records and COD increases the risk that Federal Pell Grant disbursements are not accurately recorded, reported, and reconciled. Questioned Costs – $0 Repeat Finding – No Auditor’s Perspective – Of the 60 students selected for testing, one (1) student, or 1.67% of the sample, was identified as having received less Federal Pell Grant assistance than the amount for which the student was eligible. While the exception appears isolated based on the sample tested, accurate calculation and disbursement of Federal Pell Grant eligibility is a fundamental Title IV control. The exception also identified a discrepancy between the institution's student account records and amounts reported to COD, indicating a need for strengthened controls over Pell Grant calculation and reconciliation. Auditor's Recommendation – The University should review the identified student's Federal Pell Grant eligibility for each applicable payment period and determine the exact amount of the under award. The University should make any additional disbursement for which the student remains eligible and take any necessary corrective action in COD in accordance with applicable Federal Student Aid requirements. The University should also strengthen its procedures for calculating Federal Pell Grant awards, including Year-Round Pell, and implement controls to ensure that enrollment intensity, Scheduled Award amounts, and remaining Pell eligibility are reviewed for each applicable payment period. Additionally, the University should reconcile Pell Grant disbursements recorded in the student information system and general ledger to amounts accepted by COD and investigate and resolve the $1,397 discrepancy identified for this student. 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 2025-017 1. Finding Summary The auditor identified one (1) of sixty (60) students selected for student eligibility testing who was not awarded the full amount of Federal Pell Grant funds for which the student was eligible. As a result, the institution could not demonstrate compliance with Title IV eligibility requirements, creating a risk that Federal Pell Grants funds could be awarded in an incorrect amount. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that the university should strengthen its procedures for reviewing student hours to ensure Federal Pell Grant funds are awarded in correct amount. 3. Root Cause Analysis The root cause of this finding resulted from an isolated oversight in the enrollment intensity review process and management will work to provide additional training to staff for review procedures. 4. Corrective Action(s) Management will provide additional training to staff. Description of Corrective Actions Management will provide additional training for staff in the Office of Financial Aid. Additionally, management will review the exception and award any Title IV aid determined to be underawarded. The University is also investing in a new cloud-based Enterprise Resource Planning (ERP) software designed for higher education institutions, Ellucian Colleague, which should automate the enrollment intensity and awarding process. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions mitigate the risk of aid being awarded incorrected based on enrollment intensity by strengthening and automating review procedures and ensuring staff are adequately trained to complete and document the review. 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 IZI No • If not fully implemented, expected completion date: June 30, 2027 8. Status of Corrective Action (For Prior-Year or Repeat Findings) D Fully implemented D Partially implemented D Not yet implemented Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability Continued staff training and immediate correction of any isolated exceptions including awarding/returning Title IV aid, if applicable.

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
  • 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
  • 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