Finding Text
Finding 2023-002 - U.S. Department of Education (USD), Title IV Student Financial Aid
Programs (material weakness):
Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2023; Federal Pell Grant Program, FAL No. 84.063, June 30, 2023; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2023; Federal Work-Study Program,
FAL No. 84.033, June 30, 2023.
Criteria - Federal regulations governing Title IV programs.
Condition - Instances of noncompliance were noted as more fully described in the context below.
Questioned Costs - $88,024
Context - We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs:
1) The College did not reconcile the following programs between the Office of Financial Aid and the Business Office. Per 34 CFR 685.300(b)(5).
a. Federal Pell Grant Program
b. Federal Direct Student Loans
c. Federal SEOG
2) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations Report and Application to Participate (FISAP) for the programs below:
a. Federal Pell Grant Program
b. Federal Work Study (FWS) Program
3) One (1) out of 6 students tested for withdrawals and the return of Title IV funds did not have their Title IV program funds returned within the 45-day requirement. HEA, Section 484B & 34 CFR 668.22.
4) One (1) out of 60 students had a credit balance on their account created by Title IV program funds longer than 14 days. 34 CFR 668.164(h)(1).
5) One (1) out of 60 students tested did not make satisfactory academic progress (SAP) for the academic year. The College did not provide supporting documentation for successful appeals and allowed the students to receive Title IV funding. 34 CFR 668.34. Questioned cost for this finding is: $6,198.
6) Five (5) out of 60 students tested did not have high school/GED to prove eligibility for the program they were enrolled within the College. HEA Section 484(d) and 34 CFR 668.32. Questioned cost for this finding is $41,443.
7) Four (4) out of 60 students tested were accepted as transfer students but did not have official (transfer) transcripts to prove eligibility for the program they were enrolled within the College. HEA Section 484(d) and 34 CFR 668.32. Questioned cost for this finding is $40,383.
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions as applicable.
Repeat Finding – Yes.
Auditor’s Recommendation –The College should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of processes, and policies and procedures are being updated and adhered to for compliance purposes.
View of Responsible Officials – Philander Smith College concurs with this finding, and the following action has been taken.
Philander Smith University has improved the efficiency of reconciling between the Financial Aid Office and COD by standardizing procedures. Staff have been cross trained to reduce processing delays. Financial Aid staff will coordinate with Business Office staff for notification after the Financial Aid to COD reconciliation is complete. Additionally, Financial Aid Office staff will receive additional training on areas where findings were identified. Philander Smith University is actively working to fill vacancies in the Business Office.