Finding 1240503 (2026-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2026
Accepted
2026-10-15
Audit: 414960
Auditor: KPMG LLP

AI Summary

  • Core Issue: The University failed to notify 21 students about their Federal Direct Loan disbursements on time, violating federal regulations.
  • Impacted Requirements: Notifications must be sent within 30 days before or after disbursement, as per 34 CFR 668.165(a)(2) and (3).
  • Recommended Follow-Up: Enhance internal controls to ensure timely notifications are sent, including weekly audits and improved monitoring processes.

Finding Text

Finding 2026-001 – Disbursements Federal Program: Student Financial Assistance Cluster Listing Number: 84.268 Federal Direct Loans Program Federal Agency: Department of Education Award Year: June 1, 2025 – May 31, 2026 Criteria: According to 34 CFR 668.165(a)(2), if an institution credits a student ledger account with Direct Loan, Federal Perkins Loan or TEACH Grant program funds, the institution must notify the parent or student of the anticipated date and amount of disbursement. According to 34 CFR 668.165(a)(3) an institution must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. Additionally, 2 CFR § 200.303 requires the recipient of federal funds to establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and Context: The University did not have effective internal controls to ensure required Federal Direct Loan (FDL) disbursement notifications were sent to parents or students within the required timeframe. During our testing of 40 FDL student disbursements totaling $172,884, we noted that the University did not notify 21 students, with related loan disbursements totaling $104,231, of the anticipated date and amount of their loan disbursements. Upon further review, the University determined that notifications were not sent for any Direct Loan disbursements made between mid-October 2025 through mid-May 2026. The University’s management review controls were not designed with sufficient precision to identify that the required notifications had not been sent timely. Possible Cause and Effect: The University officials determined the failure to send disbursement notifications was a result of a lack of internal controls regarding monitoring and review over FDL disbursement notifications. Failure to send required FDL disbursement notifications may prevent students or parents from receiving timely information regarding loan disbursements posted to their accounts. Isolated or Systemic: Systemic. Questioned Costs: None. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend the University enhance its system of internal control to ensure notifications of disbursements are made as required by FDL program regulations. View of Responsible Officials: Management concurs with the finding. The University acknowledges that an error in the automated processing of Federal Direct Loan disbursement notifications resulted in required notifications not being generated during a portion of the 2025-2026 academic year. The University has implemented enhanced monitoring and review procedures designed to ensure that required Direct Loan disbursement notifications are generated and provided within the timeframe required by federal regulations. These procedures include weekly auditing of Direct Loan disbursement notifications, additional review when expected notification activity is not identified, enhanced controls over nightly communication processing, and periodic manual audits of automated PeopleSoft processes. The University implemented the corrective actions described below beginning June 6, 2026. These controls are intended to provide both ongoing monitoring of required communications and independent verification that automated processes continue to operate as designed.

Corrective Action Plan

Finding #2026-001 Context Finding #2026-001 indicates that the University did not have effective internal controls to ensure required Federal Direct Loan disbursement notifications were sent to parents or students within the regulatory timeframe. 1. Interim Manual Processing of Nightly Communications Effective June 6, 2026, all nightly communications will be manually reviewed and processed until the associated PeopleSoft PSJob has been fully audited and the process changes described in this corrective action plan have been implemented and validated by multiple staff members. This interim control will remain in place until management determines that the automated process has been adequately validated and that the associated monitoring controls are operating effectively. 2. Weekly Audit of Federal Direct Loan Disbursement Notifications The Financial Aid Office will conduct a weekly audit of Direct Loan disbursement notifications using the PeopleSoft PSQuery XCFA_LN_DISB_NOTICE_AUDIT_QRY. The query will be run at the beginning of each week, normally on Monday or, when Monday is a holiday, on the next business day. The review will cover the preceding Sunday through Saturday. The reviewer will examine the results to identify Direct Loan disbursements for which the required notification was not generated or for which the notification date falls outside the applicable regulatory timeframe. Any communication for which the date of the disbursement exceeds 30 days from the date of the notification will be flagged for further review and resolution. The completed query results will be saved to: J:\PeopleSoft\Communications\Disbursement Notice Audit The file name will identify the beginning and ending dates of the period reviewed. 3. Additional Review When the Disbursement Audit Report Is Blank If the XCFA_LN_DISB_NOTICE_AUDIT_QRY produces no results for a weekly review period, an additional audit will be performed to confirm that disbursement activity occurred and that the absence of Direct Loan notifications is not the result of a system or query-processing issue. The additional report will include surrounding disbursement transactions, including non-Direct Loan disbursements, to determine whether disbursements were processed during the review period but no Direct Loan transactions were included in the notification audit. This report will be saved in the same location: J:\PeopleSoft\Communications\Disbursement Notice Audit The report will use the same date convention as the primary audit report and will have a distinct file name identifying it as the supplemental or anomalous activity review. Any unexpected result will be investigated and documented. 4. Enhanced Controls for Nightly Communication Processing Communication selection queries will be modified to include defined processing time parameters. For example, revisions older than 14 days will not be selected for automatic processing without additional review. For each communication type, a report will identify communications that fall outside the established processing window and have not already been satisfied by a successfully processed communication. A separate report will provide the communication's add date and processing status following the nightly selection and processing of the communication batch. Following completion of each communication's processing job, the applicable reports will be distributed by email to: • Alexander Musser (amusser) • Lauren Musser (musser) • Jenni Swindell (jswindel) Email subject lines will clearly identify the communication type and report type. The email body will describe the applicable processing activity and identify any exceptions requiring review. The reports and associated documentation will be reviewed and retained in: J:\PeopleSoft\Communications\Weekly Communications Files will be named using the applicable communication type, report type, and processing date. 5. Monthly Audit of Automated PeopleSoft PSJobs All automated PeopleSoft PSJobs supporting financial aid communications will be subject to a monthly control audit. The monthly review will include a manual review of each step within the applicable PSJob to verify that: • Each step remains properly configured; • Selection criteria and processing parameters remain appropriate; • The correct processes and queries are being executed; • The PSJob is running under the appropriate user account; • No unauthorized or unexplained changes have been made; and • The overall sequence and configuration of the PSJob remain consistent with the intended business process. The review will be documented in the PSJob Log, maintained in: J:\PeopleSoft\PSJobs The PSJob Log will contain a separate worksheet for each applicable PSJob and will document the PSJob's current status, configuration changes, the individual making each change, the user account under which the automation operates, and the date and time of changes. Monthly reviews, system configuration adjustments, and user-related adjustments will be documented in the log. 6. Management Monitoring Management will review the results of the weekly Direct Loan disbursement notification audits and monthly PSJob audits to identify recurring exceptions, processing failures, or trends that could indicate a deficiency in the underlying automated process. Exceptions identified through these reviews will be investigated and corrected. Where appropriate, corrective actions will include modification of the automated process, additional staff review, or modification of the monitoring control. Documentation of the reviews, exceptions, and corrective actions will be retained in accordance with the University's established record-retention practices. Expected Outcome These corrective actions are designed to provide multiple levels of control over Federal Direct Loan disbursement notifications. The combination of automated processing, weekly transaction-level review, exception reporting, supplemental review when expected activity is absent, and monthly PSJob configuration audits is intended to provide reasonable assurance that required Direct Loan disbursement notifications are generated and provided within the applicable federal timeframe and that failures in automated processing are identified promptly. Responsible Parties Jenni Swindell, Associate Director Alex Musser, Business Analyst

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Other Findings in this Audit

  • 1240502 2026-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $115.38M
84.063 FEDERAL PELL GRANT PROGRAM $11.22M
84.033 FEDERAL WORK-STUDY PROGRAM $2.12M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $1.60M
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $664,144
93.847 DIABETES, DIGESTIVE, AND KIDNEY DISEASES EXTRAMURAL RESEARCH $390,076
93.867 VISION RESEARCH $341,468
93.866 AGING RESEARCH $222,431
93.838 LUNG DISEASES RESEARCH $171,871
47.074 BIOLOGICAL SCIENCES $166,316
93.310 TRANS-NIH RESEARCH SUPPORT $137,677
47.079 INTERNATIONAL SCIENCE AND ENGINEERING $137,216
47.075 SOCIAL, BEHAVIORAL, AND ECONOMIC SCIENCES $134,699
10.001 AGRICULTURAL RESEARCH BASIC AND APPLIED RESEARCH $128,705
12.800 AIR FORCE DEFENSE RESEARCH SCIENCES PROGRAM $117,376
21.008 LOW INCOME TAXPAYER CLINICS $116,120
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $99,587
43.001 SCIENCE $99,565
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $85,025
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $84,833
10.176 DAIRY BUSINESS INNOVATION INITIATIVES $81,730
12.910 RESEARCH AND TECHNOLOGY DEVELOPMENT $65,589
47.050 GEOSCIENCES $63,434
93.855 ALLERGY AND INFECTIOUS DISEASES RESEARCH $61,456
43.012 SPACE TECHNOLOGY $60,781
11.609 MEASUREMENT AND ENGINEERING RESEARCH AND STANDARDS $59,779
12.630 BASIC, APPLIED, AND ADVANCED RESEARCH IN SCIENCE AND ENGINEERING $59,514
10.210 HIGHER EDUCATION NATIONAL NEEDS GRADUATE FELLOWSHIP GRANTS $50,980
12.420 MILITARY MEDICAL RESEARCH AND DEVELOPMENT $50,450
93.226 RESEARCH ON HEALTHCARE COSTS, QUALITY AND OUTCOMES $41,660
93.853 EXTRAMURAL RESEARCH PROGRAMS IN THE NEUROSCIENCES AND NEUROLOGICAL DISORDERS $27,753
97.061 CENTERS FOR HOMELAND SECURITY $23,220
12.300 BASIC AND APPLIED SCIENTIFIC RESEARCH $19,678
84.325 SPECIAL EDUCATION - PERSONNEL DEVELOPMENT TO IMPROVE SERVICES AND RESULTS FOR CHILDREN WITH DISABILITIES $17,456
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $16,503
45.024 PROMOTION OF THE ARTS GRANTS TO ORGANIZATIONS AND INDIVIDUALS $16,418
93.399 CANCER CONTROL $16,201
47.041 ENGINEERING $15,250
11.417 SEA GRANT SUPPORT $14,809
81.049 OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM $14,554
93.395 CANCER TREATMENT RESEARCH $13,762
47.083 INTEGRATIVE ACTIVITIES $13,449
10.310 AGRICULTURE AND FOOD RESEARCH INITIATIVE (AFRI) $11,070
93.837 CARDIOVASCULAR DISEASES RESEARCH $7,433
12.750 UNIFORMED SERVICES UNIVERSITY MEDICAL RESEARCH PROJECTS $6,895
93.839 BLOOD DISEASES AND RESOURCES RESEARCH $6,775
93.396 CANCER BIOLOGY RESEARCH $6,114
93.213 RESEARCH AND TRAINING IN COMPLEMENTARY AND INTEGRATIVE HEALTH $4,987
93.RD Strong Heart Study (SHS) - Creative Sovereignty Lab $4,605
10.699 PARTNERSHIP AGREEMENTS $4,283
93.865 CHILD HEALTH AND HUMAN DEVELOPMENT EXTRAMURAL RESEARCH $3,627
45.025 PROMOTION OF THE ARTS PARTNERSHIP AGREEMENTS $2,740
93.879 MEDICAL LIBRARY ASSISTANCE $1,166
12.431 BASIC SCIENTIFIC RESEARCH $21