Finding 2023-004
Program: Federal Work-Study Program
CFDA No.: 84.033
Federal Agency: Department of Education
Award Year: FY 2022 - 2023
Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify
students are not earning Federal Work-Study program financial aid du...
Finding 2023-004
Program: Federal Work-Study Program
CFDA No.: 84.033
Federal Agency: Department of Education
Award Year: FY 2022 - 2023
Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify
students are not earning Federal Work-Study program financial aid during scheduled class time, and that
all amounts paid are appropriately earned.
University’s Response:
The University continues to emphasize and reinforce with its students and student supervisors the
importance of not working during scheduled class hours, regardless of whether their jobs are funded by the
Federal Work Study program or by the institution. This policy applies even if classes are canceled or let out
early. The Student Employment Program holds annual training sessions for these responsible individuals
and provides updated publications. As part of the University's student employment application process,
students are required to submit their class schedules. Supervisors are expected to utilize these schedules
and ensure that work schedules do not conflict with class times. Additionally, supervisors are expected to
obtain students' class schedules each semester and update their work schedules accordingly, to prevent
students from working during class hours.
In the University’s effort to meet the FISAP correction deadline and out of an abundance of caution, all
questionable work-study transaction funds were returned and converted to institutionally full-paid hours for
these students. This action aims to avoid penalizing the students for any errors and to rectify potential
misappropriation of federal work-study funds.
Corrective Action Plan:
The University’s Student Employment Office continues to send monthly emails to student employee
supervisors and the student staff, reminding them of the student employment guidelines they are expected
to abide by. This communication emphasizes their responsibility to adhere to these guidelines and to keep
their supervisor informed of any changes to their class schedule that may require adjustments to their work
schedule. Student employee supervisors are expected to hold a mandatory meeting with their student staff
at or before the start of each semester.
The University also continues its internal audit process, implemented in February 2023. A sample of student
work records from the previous semester will be compared to students’ class schedules to ensure they are
not working during class hours. This review will be conducted by Brad Calloway, Senior Vice President for
Business Affairs. Any violations of the school's student employment policies identified in this audit will be
reported to Marc Sears, Vice President of Human Resources, for necessary corrective action. In mid-January 2024, the University will institute the Give Pulse platform, which will integrate with the
University’s current HR/Payroll timekeeping system, Workday. The Give Pulse platform will assist in
flagging students whose work hours fall outside the parameters of hours worked. Further training and
instruction to pay closer attention to these discrepancies, such as failing to clock out or working for eight or
more hours in a day, will be provided to student employee supervisors as part of the monthly email
communication.
The University is investigating the feasibility of implementing parameters within Workday that would notify
student supervisors when their student workers are clocked in for more than 8 hours straight as well as
when they are nearing 20 hours of work in a week. This notification would enable supervisors to ensure the
accuracy of their students' clocked hours and make adjustments if necessary.
Name of Responsible Person: Jonathan Mador, Assistant Vice President of Student Financial Services;
Sandra Fantauzzi, Student Employment Program Manager; Marc Sears, Vice President of Human
Resources; Brad Calloway, Senior Vice President for Business Affairs
Anticipated Completion Date: February 29, 2024