Finding 1240497 (2025-010)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-10-15
Audit: 414959
Organization: Heritage University (WA)

AI Summary

  • Core Issue: There is a material weakness in internal controls over compliance related to the reporting of student financial aid disbursements.
  • Impacted Requirements: The University failed to accurately report disbursement amounts and dates to the Common Origination and Disbursement (COD) system for Title IV aid.
  • Recommended Follow-Up: Implement stronger controls to ensure accurate application of disbursements and timely reporting to COD, with management reviewing processes between Financial Aid and Student Accounts.

Finding Text

2025-010 – Reporting – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Department of Education Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Federal Award Number: P063P242403, P268K252403 Award Year: 2024-25 Criteria – Institutions submit Direct Loan and Pell Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. The University is responsible for accurately reporting origination and disbursement records including disbursement date and amount. Condition/context – We selected a sample of 41 students out of a population of 742 students who received Title IV aid during the year. Of the 41 samples selected we found the following errors with the disbursement records reported to COD: • 3 students had amounts reported to COD for direct loan or Pell disbursements that did not match the amount disbursed per the student account records. 2 students had account records that reflected less direct loan disbursements than were reported to COD for a total of $6,532 and one student reported an additional $924 in Pell and an extra $6,185 in direct loan disbursements per their student account records than was reported to COD. • 33 students had disbursement dates reported to COD for direct loans or Pell disbursements that did not match the date applied per the student account records. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None Cause/effect – This occurred because of turnover in the student financial assistance office and a lack of properly documented and implemented control policies and procedures to ensure accurate application of disbursements to student records, and accurate and timely reporting of disbursements to COD. Repeat finding – No Recommendation – We recommend the University implement the proper controls to ensure that disbursements are accurately applied to student accounts and reported to COD accurately and timely. Views of responsible officials and planned corrective actions – Heritage University agrees with the recommendation and is strengthening its controls over the disbursement and reporting of Title IV funds. Management is reviewing the processes between Financial Aid and Student Accounts to ensure disbursements are accurately applied to student accounts and reported to COD completely, accurately, and within required timeframes.

Corrective Action Plan

10. 2025-010 – Reporting – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement the proper controls to ensure that disbursements are accurately applied to student accounts and reported to COD accurately and timely. Planned corrective actions: Heritage University agrees with the recommendation and is strengthening its controls over the disbursement and reporting of Title IV funds. Management is reviewing the processes between Financial Aid and Student Accounts to ensure disbursements are accurately applied to student accounts and reported to COD completely, accurately, and within required timeframes. As part of this work, the University is establishing clearer ownership, defined timelines, and documented checkpoints for reviewing and reconciling disbursement activity between the financial aid system, student accounts, and COD. Responsibilities will be assigned for identifying and resolving discrepancies and ensuring required corrections are completed timely. The University will also incorporate documented review and reconciliation procedures into its Financial Aid processes and continue to evaluate staffing, training, system access, and workload to ensure employees have the capacity and resources necessary to consistently perform these compliance responsibilities. Name of Responsible Party: Nancy Benavidez, Sagrario Armenta Jimenez Anticipated completion date: Most of the clean-up will happen during Fiscal Year 2026-2027. But this will always remain a project for continuous improvement.

Categories

Student Financial Aid

Other Findings in this Audit

  • 1240464 2025-002
    Material Weakness Repeat
  • 1240465 2025-002
    Material Weakness Repeat
  • 1240466 2025-003
    Material Weakness Repeat
  • 1240467 2025-003
    Material Weakness Repeat
  • 1240468 2025-004
    Material Weakness Repeat
  • 1240469 2025-004
    Material Weakness Repeat
  • 1240470 2025-004
    Material Weakness Repeat
  • 1240471 2025-004
    Material Weakness Repeat
  • 1240472 2025-004
    Material Weakness Repeat
  • 1240473 2025-004
    Material Weakness Repeat
  • 1240474 2025-004
    Material Weakness Repeat
  • 1240475 2025-004
    Material Weakness Repeat
  • 1240476 2025-004
    Material Weakness Repeat
  • 1240477 2025-004
    Material Weakness Repeat
  • 1240478 2025-005
    Material Weakness Repeat
  • 1240479 2025-005
    Material Weakness Repeat
  • 1240480 2025-005
    Material Weakness Repeat
  • 1240481 2025-006
    Material Weakness Repeat
  • 1240482 2025-006
    Material Weakness Repeat
  • 1240483 2025-006
    Material Weakness Repeat
  • 1240484 2025-006
    Material Weakness Repeat
  • 1240485 2025-007
    Material Weakness Repeat
  • 1240486 2025-007
    Material Weakness Repeat
  • 1240487 2025-008
    Material Weakness Repeat
  • 1240488 2025-008
    Material Weakness Repeat
  • 1240489 2025-008
    Material Weakness Repeat
  • 1240490 2025-008
    Material Weakness Repeat
  • 1240491 2025-008
    Material Weakness Repeat
  • 1240492 2025-008
    Material Weakness Repeat
  • 1240493 2025-008
    Material Weakness Repeat
  • 1240494 2025-009
    Material Weakness Repeat
  • 1240495 2025-009
    Material Weakness Repeat
  • 1240496 2025-010
    Material Weakness Repeat
  • 1240498 2025-011
    Material Weakness Repeat
  • 1240499 2025-011
    Material Weakness Repeat
  • 1240500 2025-011
    Material Weakness Repeat
  • 1240501 2025-011
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $3.79M
84.268 FEDERAL DIRECT STUDENT LOANS $3.25M
84.184 SCHOOL SAFELY NATIONAL ACTIVITIES $1.32M
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $535,630
84.031 HIGHER EDUCATION INSTITUTIONAL AID $495,537
84.141 MIGRANT EDUCATION HIGH SCHOOL EQUIVALENCY PROGRAM $494,528
84.149 MIGRANT EDUCATION COLLEGE ASSISTANCE MIGRANT PROGRAM $453,194
84.042 TRIO STUDENT SUPPORT SERVICES $263,859
84.217 TRIO MCNAIR POST-BACCALAUREATE ACHIEVEMENT $218,194
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $104,462
84.033 FEDERAL WORK-STUDY PROGRAM $90,480
10.310 AGRICULTURE AND FOOD RESEARCH INITIATIVE (AFRI) $48,248
10.558 CHILD AND ADULT CARE FOOD PROGRAM $33,141
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $30,407
43.001 SCIENCE $13,280
47.074 BIOLOGICAL SCIENCES $7,041