FINDING 2022 – 003:
Repeat of Prior Year Finding 2021-008
Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid
Type of Finding: Overaward of Title IV Funds
Criteria: Title IV regulations (34 CFR 685.203) states in no case may Direct Subsidized, Direct
Unsubsidized, or Direct PLUS Loan amount exceed the student’s estimated cost of attendance for the
period of enrollment for which the loans were intended, less (1) the student’s estimated financial
assistance for that period and (2) the borrower’s expected family contribution for that period.
Condition: During testing the auditors noted two instances where the University awarded a Direct
Unsubsidized loan to a student that caused the student’s financial assistance received to be greater
than the student’s cost of attendance.
Corrective Action: At the time of these findings, all Wheeling University Financial Aid processing
operations were being conducted manually. The high level of complexity commonly associated with
financial aid processing creates an environment, especially when conducted in a manual format, that is
error-intrinsic. Packaging and awarding for each of the federal student aid programs are currently
conducted by using the student information system, Colleague, which allows the FA office to perform
these processing operations in a fully automated manner. Proper use of the “auto-packaging” feature
provides significant assurance that student awards will not exceed financial need based on Cost of
Attendance (COA) and Estimated Family Contribution (EFC). Previous audit findings have noted a general
lack of accuracy, organization, and documentation regarding the final figure for the COA, which can
result in packaging and over-award errors. As such, the Acting Director of Financial Aid has completely
extensively researched and input data into the system with an accurate, fair, and equitable formula for
arriving at a COA while meeting student need and, consequently, reducing or eliminating the potential
for over-awards. This data was obtained from state and local cost of living figures, input from other
similar state schools, and by use of the higher education organization, the College Board. This data is
available as a reference for future documentation and review in a shared electronic file.
Anticipated Completion Date: This process was completed in March of 2023 and is ongoing.