Finding 1240820 (2026-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2026
Accepted
2026-10-21
Audit: 415146
Organization: Northwest University (WA)
Auditor: CLARK NUBER PS

AI Summary

  • Core Issue: There is a significant deficiency in internal controls regarding the reporting of verification status for Pell Grant recipients.
  • Impacted Requirements: The University failed to report verification status for two Pell recipients selected for verification, violating 34 CFR 668 Subpart E.
  • Recommended Follow-Up: Collaborate with the software administrator to fix the reporting issue and implement a manual review process for all Pell recipient verifications.

Finding Text

Significant deficiency in internal controls over compliance with verification requirements. Federal Agency: U.S. Department of Education Program Title: Federal Pell Grant Programs Assistance Listing Number: 84.063 Award Period: 2025-26 Criteria Per 34 CFR 668 Subpart E, for Federal Pell Grant (Pell Grant) awards that the school disbursed to a student selected for verification, the school must report the student’s verification status to the Department of Education (ED) via the Common Origination and Disbursement (COD) System. Condition/Context for Evaluation We selected a sample of five students who were selected for verification during the 2025-2026 fiscal year. We noted that two of the sampled students were Pell recipients, and we found that verification status had not been reported in the COD system. The University determined that this was due to an error in their financial aid management software in which the Verification Status Code was not flowing through to COD reporting for school- selected verifications (though it was for FAFSA Processing System-selected students). A manual review was not performed to ensure that verification status was appropriately reported in the COD for all Pell recipients. Effect or Potential Effect The University did not correctly report the verification status of Pell recipients who were selected for verification by the school. An internal audit was performed over 2025-2026 verifications, and management determined that error was isolated to the two students selected for audit as these were the only Pell recipients selected by the school for verification. Questioned Costs None noted. Repeat Finding Not applicable. Recommendation We recommend that the University work with financial aid management software administrator to ensure that verification status flows through to COD reporting whether students are school or FAFSA Processing System- selected. In addition, we recommend that the University implement a manual review of COD reporting for Pell recipients to ensure correct reporting. Views of Responsible Officials Management concurs with the finding and has provided the accompanying corrective action plan.

Corrective Action Plan

NORTHWEST UNIVERSITY Corrective Action Plan For the Year Ended May 31, 2026 Finding Number 2026-001: Significant deficiency in internal controls over compliance with verification requirements. Significant deficiency in internal controls over compliance with verification requirements: For the two students who received Pell grants of five total students selected for verification testing, verification status was not correctly coded in Common Origination and Disbursement (COD) system. This was the result of an issue in PFAIDS in which verification status code is only reporting for Pell recipients who were selected for verification by the FPS, not for students selected by the school. SFS has reviewed the scope of this issue and determined that these were the only two Pell recipients who were school-selected and verified, and the Verification Status Code for both students has been updated in COD as of 8/11. Contact Person(s): Cynthia Kennedy, Director of SFS; Ryan Porter, CFO; and Bernie Rundquist, Controller Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: The compliance issue was the result of a reporting error within the University’s current financial aid management system. Student Financial Services (SFS) is transitioning to a new financial aid management system in October 2026 and has ensured that the verification status flows correctly through COD reporting. The University goes live with the new system for the 2027-2028 award year. For the remainder of the current 2026-2027 reporting cycle, SFS has implemented a regularly scheduled manual review of COD reporting for students who are school-selected for verification to ensure correct reporting. This review will continue through the duration of processing in the current system. Anticipated completion date: October 2026

Categories

Student Financial Aid Reporting Significant Deficiency Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $15.39M
84.063 FEDERAL PELL GRANT PROGRAM $2.57M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $71,760