Finding 1240297 (2025-018)

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

AI Summary

  • Core Issue: The University failed to document required entrance and exit counseling for four students, leading to noncompliance with federal Direct Loan requirements.
  • Impacted Requirements: Compliance with 34 CFR § 685.304(a) and (b) for entrance and exit counseling documentation is necessary to inform borrowers of their rights and obligations.
  • Recommended Follow-Up: Strengthen monitoring and documentation procedures for counseling requirements to ensure compliance and verify completion before loan disbursements and upon student exit.

Finding Text

Finding 2025-018 – U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Failure to Document Required Direct Loan Entrance and Exit Counseling (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 § 685.304(a), an institution must ensure that entrance counseling is provided to first-time student borrowers of Federal Direct Subsidized and Unsubsidized Loans prior to the borrower receiving the first disbursement of a Direct Loan, as applicable. Additionally, 34 CFR § 685.304(b) requires an institution to provide exit counseling to Direct Loan borrowers shortly before the student ceases at least half-time enrollment, including when the student graduates or withdraws. When a student leaves without the institution's prior knowledge or fails to complete counseling, the institution must provide the required exit counseling information in accordance with federal requirements. Further, 34 CFR § 668.24 requires institutions to establish and maintain records sufficient to demonstrate compliance with Title IV program requirements. Condition – During testing of Federal Direct Loan requirements, we noted that the University was unable to provide documentation demonstrating completion of required loan counseling for four students, as follows: • Two (2) students did not have documentation supporting completion of required entrance counseling; and • Two (2) students did not have documentation supporting completion or provision of required exit counseling. As a result, the University was unable to demonstrate compliance with applicable Federal Direct Loan counseling requirements for the students identified. Cause – The exceptions appear to have resulted from insufficient procedures for monitoring completion of required Direct Loan entrance and exit counseling and maintaining documentation supporting compliance with federal counseling requirements. Effect – Failure to ensure and document required entrance and exit counseling results in noncompliance with Federal Direct Loan program requirements and increases the risk that student borrowers may not receive required information regarding their rights and responsibilities, repayment obligations, loan terms, and available repayment options. Questioned Costs – $0 Repeat Finding – No Auditor’s Perspective – Of the 60 students selected for testing, four (4) students, or 6.67% of the sample, did not have documentation supporting compliance with applicable Direct Loan counseling requirements. Specifically, two students lacked documentation of required entrance counseling, and two students lacked documentation supporting required exit counseling. The exceptions indicate a weakness in the University's procedures for monitoring and documenting compliance with Federal Direct Loan counseling requirements. However, based on the sample tested, the exceptions alone do not necessarily indicate a pervasive or systemic failure of the University's Direct Loan counseling process. Auditor's Recommendation – The University should strengthen its procedures for monitoring and documenting Federal Direct Loan entrance and exit counseling requirements. Financial Aid personnel should establish procedures to verify completion of required entrance counseling prior to applicable loan disbursements and to ensure that exit counseling is completed or that required counseling materials are provided within applicable federal timeframes when borrowers graduate, withdraw, or cease at least half-time enrollment. 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 2025-018 1. Finding Summary The auditor determined that the institution did not consistently obtain or maintain documentation confirming that required Direct Loan entrance and exit counseling was completed for applicable borrowers. As a result, the institution could not demonstrate compliance with federal Direct Loan counseling and Title IV record retention requirements. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that documentation of required Direct Loan entrance and exit counseling was not consistently obtained or maintained in student files in accordance with federal requirements. 3. Root Cause Analysis The root cause of this finding resulted from the absence of a formal process to verify completion of entrance and exit counseling, failure to reconcile COD counseling completion reports with student records, and insufficient internal controls to prevent loan disbursement or separation processing without required counseling documentation. 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 The institution has implemented standardized checklists and workflows to ensure required Direct Loan entrance and exit counseling is completed and documented. A supervisory or secondary review has been added prior to loan processing or student separation, and periodic internal monitoring and quality assurance reviews have been established to verify ongoing compliance with federal counseling and documentation requirements. Implementing the revised process has been delayed due to personnel changes. Additionally, the University has contracted with Blue Icon Advisors, a National Association of Student Financial Aid Administrators' financial aid consulting service, to review the review process and assist with implementation. Finally, the University is investing in a new cloud-based Enterprise Resource Planning (ERP) software designed for higher education institutions, Ellucian Colleague, which should automate notifications and account flags for missing documents. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions mitigate the risk of disbursing Direct Loan funds or processing student separations without required counseling by strengthening documentation verification, supervisory oversight, and file review processes. Ongoing monitoring and quality assurance reviews further reduce compliance risk and support sustained adherence to federal Direct Loan counseling 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: D Yes 1:8:Nl o • 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 1:8:Nl 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 to ensure loan counseling is obtained timely. Continued staff training, standardized workflows, and quality assurance reviews will be sustained to support long-term compliance and promptly identify and address any documentation deficiencies.

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
  • 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
  • 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