Finding 537875 (2024-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-27
Audit: 348957
Organization: Xavier University (OH)

AI Summary

  • Core Issue: The university lacks proper internal controls to retain notifications about title IV fund disbursements to students.
  • Impacted Requirements: Failure to comply with 34 CFR 668.165(a)(1) may result in noncompliance with federal funding conditions.
  • Recommended Follow-Up: Implement processes to maintain evidence of compliance controls to support federal grant requirements.

Finding Text

2024 ‐ 001: Significant Deficiency in Internal Controls over Compliance and Noncompliance— Special Tests and Provisions - Disbursement to or on Behalf of Students. Federal Program – Student Financial Aid Cluster Federal Agency – U.S. Department of Education Criteria — In accordance with 34 CFR 668.165(a)(1), before an institution disburses title IV funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV program and how and when those funds will be disbursed. Condition and Perspective — The university did not have adequate internal controls to ensure the notifications to students regarding the disbursements of title IV funds were retained. Accordingly, we could not verify if the university appropriately notified the students of the disbursements. Cause — The university has an automated process that notifies the students of their receipt of title IV funds. Once the process is executed, the output or result is overwritten daily, thereby deleting all evidence of the notification process. Effect — The failure to maintain adequate evidence of the design, implementation and operation of controls over compliance could lead to noncompliance with the terms and conditions of federal awards and potential loss of funding. Questioned Cost — N/A Recommendation — The university should design processes to ensure that evidence of their controls design, implementation and operation are maintained to support the compliance with the terms and conditions of their grant awards. View of Responsible Officials — See Corrective Action Plan.

Corrective Action Plan

Corrective Action Plan Xavier complies with the loan disbursement notification rules. During the audit we learned that, while our system was sending the emails to each student with a loan disbursement, our process for copying each individual email to xufinaid was not functioning. Further, the notification report was being overwritten daily, causing us to lose the audit trail for these notifications. We have implemented two steps to be able to document each individual email. 1. The xufinaid@xavier.edu email address is copied on every disbursement notification and each notification email is delivered into the xufinaid inbox in Outlook. Every Wednesday those emails are moved by financial aid personnel into a folder in Outlook where they remain stored. This weekly review allows personnel to know in a timely manner if there are issues with the email delivery process. 2. A log file which saves a list of the disbursement notification emails is saved on a daily basis. It includes the content of each email.

Categories

Special Tests & Provisions Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1114317 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $39.83M
84.063 Federal Pell Grant Program $4.36M
10.025 Plant and Animal Disease, Pest Control, and Animal Care $477,597
84.033 Federal Work-Study Program $444,733
84.007 Federal Supplemental Educational Opportunity Grants $384,110
84.042 Trio Student Support Services $269,995
84.425U Education Stabilization Fund $169,531
84.038 Federal Perkins Loan Program $91,990
84.027 Special Education Grants to States $91,152
21.027 Coronavirus State and Local Fiscal Recovery Funds $85,480
93.264 Nurse Faculty Loan Program (nflp) $76,609
47.076 Stem Education (formerly Education and Human Resources) $70,180
97.132 Financial Assistance for Targeted Violence and Terrorism Prevention $51,741
43.007 Space Operations $49,289
17.268 H-1b Job Training Grants $41,337
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $40,587
19.009 Academic Exchange Programs - Undergraduate Programs $34,293
84.323 Special Education - State Personnel Development $34,090
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $27,041
84.305A Education Research, Development and Dissemination $18,291
94.006 Americorps State and National 94.006 $7,791