Finding 1240501 (2025-011)

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

AI Summary

  • Core Issue: The University failed to provide a complete list of students selected for verification, leading to a material weakness in internal controls over compliance.
  • Impacted Requirements: The institution did not adhere to the necessary policies for verifying applicant information as outlined in federal regulations.
  • Recommended Follow-Up: Implement stronger controls for accurate student verification and ensure procedures are well-documented and consistently applied.

Finding Text

2025-011 – Special Tests and Provisions - Verification – 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, 84.033, 84.007 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work Study, Federal Supplemental Educational Opportunity Grant Federal Award Number: P063P242403, P033A244364, P268K252403, P007A244364 Award Year: 2024-25 Criteria – An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by ED. The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. Condition/context – The University was unable to provide an accurate and complete population of students selected for verification during fiscal year 2024-2025. We selected one student during the year who was verified for testing. Based on a review of the support provided and discussion with management, it was determined that the verification was missing salary information for the dependent student’s parents. The University did not follow up on the discrepancy between the student’s verification request and the information reported in the students Institutional Student Information Record (ISIR). Questioned costs – Undeterminable, as the information was not verified, we are not able to determine if the need based aid would have been effected. 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 that students selected for verification are properly reviewed and verified. Repeat finding – No Recommendation – We recommend the University implement the proper controls to ensure that verification of students is completed accurately and according to the applicable guidance. Views of responsible officials and planned corrective actions – Heritage University agrees with the recommendation and is strengthening its processes and internal controls surrounding student verification. As part of the University's broader efforts to build capacity within the Financial Aid department, management is reviewing existing verification procedures to ensure requirements are clearly documented, consistently applied, and aligned with applicable federal guidance.

Corrective Action Plan

11. 2025-011 – Special Tests and Provisions - Verification – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement the proper controls to ensure that verification of students is completed accurately and according to the applicable guidance. Planned corrective actions: Heritage University agrees with the recommendation and is strengthening its processes and internal controls surrounding student verification. As part of the University's broader efforts to build capacity within the Financial Aid department, management is reviewing existing verification procedures to ensure requirements are clearly documented, consistently applied, and aligned with applicable federal guidance. The University is establishing clearer ownership of verification responsibilities, defined timelines and checkpoints for completion, and appropriate review procedures to ensure required documentation is obtained and reviewed before verification is considered complete and aid is disbursed. Management will also continue to strengthen staff training and supervisory review and will periodically review procedures as federal requirements change. These efforts are intended to provide greater consistency, accountability, and oversight while ensuring verification requirements are completed accurately and timely. 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 Special Tests & Provisions Material Weakness

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
  • 1240497 2025-010
    Material Weakness Repeat
  • 1240498 2025-011
    Material Weakness Repeat
  • 1240499 2025-011
    Material Weakness Repeat
  • 1240500 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