Finding 1240606 (2026-001)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2026
Accepted
2026-10-16
Audit: 415006
Organization: Oral Roberts University (OK)
Auditor: HOGANTAYLOR LLP

AI Summary

  • Core Issue: The University requested and received about $508,000 in federal loan funds that exceeded immediate cash needs, violating federal regulations.
  • Impacted Requirements: The University failed to return excess cash within the required seven-day period, as outlined in Title 34 Section 668.166 (b).
  • Recommended Follow-Up: Improve the accuracy of financial aid feed reports to prevent duplicates and establish timely review processes to ensure compliance with cash return requirements.

Finding Text

Finding: Item 2026-001 – Cash Management Federal Program – Federal Direct Loans Federal ALN – 84.268 Federal Award Year – April 30, 2026 Federal Agency – U.S. Department of Education (DOE) Pass-through Entity – Not Applicable Criteria: Title 34 Section 668.162 (b) states that an institution's request for funds may not exceed the amount of funds the institution needs immediately for disbursements the institution has made or will make to eligible students and parents. An institution must disburse funds requested under the advance payment method as soon as administratively feasible, but no later than three business days following the date the institution received those funds. Title 34 Section 668.166 (b) states that an institution may maintain for up to seven days an amount of excess cash that does not exceed one percent of the total amount of funds the institution drew down in the prior award year. The institution must return immediately any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account after the seven-day tolerance period. Condition: During late April of 2026, the University requested and received approximately $508,000 of Federal Direct Loan funds in excess of the funds disbursed to eligible students. The excess funds were identified by the University during reconciliation procedures in May and were returned to the DOE in June of 2026, which was beyond the seven-day tolerance period. Cause: The amount requested from the DOE was based on financial aid feed reports provided to the Finance Department. The feed reports used in the calculation contained duplicate entries, which resulted in the University overstating its immediate cash needs. Turnover in the position responsible for reviewing and providing the feed reports to the Finance Department led to a disruption in the timing and process used to generate and send the feed reports to the Finance Department.Repeat finding: Not a repeat finding. Questioned costs: The University returned $507,559 after the allowable period. Effect: The University had approximately $508,000 in federal funds before they were needed and did not comply with the requirement to return the excess cash to the DOE within seven days. Recommendation: We recommend the University improves the process for developing the feed reports, which are provided to the University's Finance Department, to ensure duplicate entries cannot occur in future periods. We also recommend review and reconciliation controls are performed timely so that any excess funds can be returned to the DOE within the required timeframe. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.

Corrective Action Plan

Identifying Number: Item 2026-001 - Cash Management Finding During late April of 2026, the University requested and received approximately 508,000 of Federal Direct Loan funds in excess of the funds disbursed to eligible students. The excess funds were identified by the University during reconciliation procedures in May and were returned to the DOE in June of 2026, which was beyond the seven-day tolerance period. Management's Response The University agrees with the above referenced findings and is committed to maintaining compliance with the cash management requirements. Corrective Action Plan Management agrees with the recommendation that the University should improve the process utilized to generate the Financial Aid Feed Report (Feed Report). The corrective action will include two additional controls, one in the Financial Aid Office focused on generating accurate reports, and one in the Finance Department focused on ensuring the information contained in the Feed Report is accurate prior to submitting the reimbursement request to the U.S. Department of Education. Both of these additional controls are considered "prevent" controls as both are designed to prevent errors prior to seeking cash/reimbursement from the U.S. Department of Education. The added "prevent" controls are summarized as follows: 1. Financial Aid Department - To help prevent inaccurate information from being generated on the Feed Report, the Financial Aid Office has partnered with the University's Information Technology Department to automate the creation and distribution of the following reports to designated Financial Aid and Finance personnel on a regular basis. This automation will improve cash flow by providing Feed Reports in a more timely manner and will reduce reliance on manual processes previously utilized to generate and distribute the below referenced reports. · Weekly financial aid feed reports identifying Pell Grant, Federal Supplemental Educational Opportunity Grant (FSEOG), and Direct Loan disbursements posted to student accounts. · Monthly "year-to-date" feed reports for these same federal aid programs. The above automations are scheduled to begin following the University's upcoming Banner Cloud system go-live date on October 15, 2026. Prior to implementation of these automated processes, Financial Aid and Finance personnel are performing additional review and reconciliation procedures prior to the submission of the Feed Reports to the U.S. Department of Education to double check and confirm the accuracy of the information included in the Feed Reports. 2. Finance Department - The Finance Department will reconcile the information included on the Feed Reports with the University's general ledger thereby verifying the information received on the feed reports from Financial Aid matches the amount that has been posted to the general ledger prior to requesting the reimbursement from the U.S. Department of Education. Neal Stenzel, Chief Financial Officer, is responsible for the corrective action plan and the anticipated completion date is October 2026.

Categories

Cash Management

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $30.08M
84.063 FEDERAL PELL GRANT PROGRAM $10.44M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $5.26M
84.031 HIGHER EDUCATION INSTITUTIONAL AID $522,150
84.033 FEDERAL WORK-STUDY PROGRAM $421,843
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $377,611