Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-002 Audit Finding: As part of the audit for the 2021- 2022 Federal award year, Schneider Downs determined that the University used the same determ...
Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-002 Audit Finding: As part of the audit for the 2021- 2022 Federal award year, Schneider Downs determined that the University used the same determination for the payment period for those students who had been awarded Pell grants that it had been using in the periods for which the U.S. Department of Education (ED) conducted the Focused Program Review (FPR). In addition to the population of students who are participating the Second Chance Pell program, the University also identified additional students, that when using ED?s interpretation of the Code of Federal Regulations (CFR), the University used a payment period that did not reflect enrollment in a nonstandard instructional term program. Corrective Actions Taken or Planned: Management does not concur with the criteria of this finding due to a disagreement with the interpretation of the regulations included in ED?s Final Program Review Determination (FPRD) and has appealed the finding as stated in the following paragraphs. Management followed the direction received from the ED Reviewers during the FPR exit interview on September 24, 2021, stating the University should not change its practice for the Second Chance Pell students enrolled in their respective instructional program nor the calculation using Formula 1 for the payment period until the Program Review Report (PRR) is received. The PRR was received on January 3, 2022, which was after the summer and fall 2021 semesters and just weeks prior to the start of the spring 2022 semester. Moreover, pursuant to the Higher Education Act ?498A(b), the University was entitled to an opportunity to review the PRR and within 60 days of receipt, submit a response for ED?s review prior to their preparing a final determination. The University submitted its response to the PRR on March 11, 2022. The University disagrees with the determinations in the FPRD and is vigorously defending itself against the ED interpretation of the regulations, the findings and the proposed financial assessments. The University filed an appeal of the findings and the associated financial assessments contained in the FPRD on October 24, 2022, and submitted a brief in support of the appeal on January 22, 2023, to the ED Office of Hearings and Appeals within the guidelines as prescribed by the Higher Education Act ? 487(b)(2) and U.S.C. ? 1094(b)(2). Effective with the fall 2022 semester term and each fall and spring terms thereafter, the Second Chance Pell students enrolled in their respective instructional programs have a fifteen (15) week standard instructional term and the payment period qualifies for calculations utilizing Pell Formula 1.