Audit 389943

2025-001 – FWS Community Service Requirements Assistance Listing Number: 84.033 – U.S. Department of Education – Federal Work Study (FWS) Program Criteria According to 34 CFR 675.18(g)(1), a school that participates in the FWS Program is required to expend at least seven percent (7%) of its FWS federal allocation to pay the federal share of wages to students employed in community service jobs in an award year. A school is also expected to provide the institutional share of wages to students employed in community service jobs. In addition, one or more of the school's FWS students must be employed as a reading tutor for children in a reading tutoring project or performing family literacy activities in a family literacy project. Condition Section 443(b)(2)(A) of the Higher Education Act of 1965, as amended (HEA) and the corresponding regulations at 34 CFR 675.18(g) set forth the Federal Work Study (FWS) community service expenditure requirements that a school must meet unless the school is granted a waiver from the Secretary. The University had no waiver and no community service or reading tutor programs for 2024-2025.Context The University does not have a waiver for 2024-2025 and did not offer community service or reading tutor programs for the 2024-2025 year. Cause Beginning with the 2024–25 award year, schools that are unable to meet the community service expenditure requirements must apply for a waiver. The University did not submit a waiver application for 2024–25.Effect A school that fails to meet FWS community service requirements may be required to return FWS federal funds in an amount that represents the difference between the amount the school should have spent for community service and the amount it actually spent, subject to a substantial fine, and/or subject to other sanctions, including a Limitation, Suspension, and Termination (L, S, & T) proceeding, through which the school could be denied future participation in the FWS Program, and possibly other Title IV, HEA programs. Questioned Costs 7% of FWS federal allocation - $5,100 Recommendation We recommend that the University ensure compliance with community service expenditure requirements by allocating at least 7% of its FWS funds to employ students in community service jobs, including at least one FWS student serving as a reading tutor for a children’s reading program. If the University is unable to meet these requirements, it must apply for an FWS Community Service Waiver. Planned Corrective Action The Office of Financial Aid has implemented a formal annual review process to determine whether Golden Gate University should request a waiver of the Federal Work-Study (FWS) expenditure requirement for the upcoming waiver period. Each February, the Associate Director of Financial Aid and the Senior Director of Student Financial Services will evaluate projected spending and decide if a waiver is necessary. If a waiver is required, it will be submitted within the designated deadline, which typically falls between March and April each year. Implementation Date This process was implemented for the 2025 - 2026 award year. A waiver request was submitted in April 2025, and approval from the Department of Education was received on June 17, 2025. For the 2026 - 2027 award year, we plan to submit the waiver request in April 2026. Responsible Personnel The Associate Director of Financial Aid and the Senior Director of Student Financial Services will work collaboratively to ensure annual compliance with this requirement. Gabriela De la Vega Senior Director Student Financial Services gdelavega@ggu.edu