I. Finding 2024-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs
(material weakness):
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) 11 out of 60 st...
I. Finding 2024-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs
(material weakness):
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) 11 out of 60 students did not meet 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 costs for this
finding is $180,794.
2) Nine (9) of the 10 students tested for Federal Work-Study Payroll had missing and/or
incomplete timesheets. 34 CFR Part 675.
3) Six (6) of the 10 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) Entrance and exit counseling documentation was not provided for first time borrowers,
withdrawn students or graduated students. 34 CFR 685.304.
5) Cost of Attendance Budgets to determine students unmet need were not provided by the
College. 34 CFR 685.102(b).
6) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations
Report and Application to Participate (FISAP) for Federal Pell Grant, Federal SEOG and Federal
Work-Study.
7) The College did not reconcile all Title IV programs between the Office of Financial Aid and the
Business Office including Federal Pell Grant, Federal SEOG, Federal Work-Study and Federal
Direct Loans. CFR 685.300(b)(5).
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.
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.
Corrective Action – Tougaloo College Administration understands the importance of federal
compliance. The collective knowledge of others within the Division of Finance and
Administration reinforces the expertise of the four financial aid staff members. The Vice
President of Finance and Administration, in collaboration with the Vice President for Enrollment
and Student Services, who has direct oversight of the financial aid department, has
implemented professional development targeted training on the continuous changes in Title IV
program management. In addition to addressing/paying the questioned costs found with
improper documentation of Satisfactory Academic Progress with USDE, the following allows for
corrective actions while continuing to engage with the Title IV student financial aid programs:
1. Financial Aid team members become certified in the enterprise resource program module,
specific to financial aid.
2. Annually, one or more staff members attend the national conference for student aid
administrators, which focuses on deepening understanding of federal regulations, exploring
new legislation enacted by Congress, gaining practical experience with student loan data
systems, and networking with industry peers who offer support identifying and effectively
addressing challenges associated with financial aid operations.
3. Attend monthly and quarterly training via knowledge base webinars on: Satisfactory
Academic Progress (SAP), Work-study process for students and staff, student loan process,
the return of Title IV funds, and reconciling expenditures with the Business Office.
4. Utilize additional resources from the U.S. Department of Education’s Minority-Serving and
Under-Resourced Schools Division for administering Title VI Aid.