Finding 1062550 (2024-002)

Significant Deficiency
Requirement
N
Questioned Costs
$1
Year
2024
Accepted
2024-09-08
Audit: 318751
Organization: Abilene Christian University (TX)

AI Summary

  • Core Issue: The University violated its Program Participation Agreement by making incentive payments to employees involved in student recruitment and financial aid decisions.
  • Impacted Requirements: Compliance with the ban on incentive compensation as outlined in 34 CFR 668.14(b)(22)(i) was not maintained.
  • Recommended Follow-Up: Review and strengthen controls and procedures to ensure adherence to the PPA, including monitoring the new tenured bonus structure.

Finding Text

Federal Pell Grant Program, Assistance Listing Number 84.063 Federal Direct Student Loans, Assistance Listing Number 84.268 Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007, Federal Work Study Program, Assistance Listing Number 84.033 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing Number 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Incentive Compensation (34 CFR 668.14(b)(22)(i). An institution agrees in its Program Participation Agreement (PPA) that it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA program funds. Condition – The University’s processes did not ensure that incentive payments were not made for covered activities under the ban on incentive compensation. Questioned costs – $2,000 Context – Out of the population of 339 employees in the University’s admissions/recruiting, financial aid, and registrar offices (or the equivalent of those offices), the University made supplemental payments to 4 employees related to covered activities under the ban on incentive compensation. The sample was not, and was not intended to be, statistically valid. Effect – the University was not in compliance with its PPA during the year. Cause – There was a lack of communication or understanding of the requirements to all of the departments impacted. Identification as repeat finding, if applicable – N/A Recommendation – Controls and procedures should be reviewed to ensure compliance with the PPA. Views of responsible officials and planned corrective actions – Management acknowledges and understands the findings related to the Incentive Compensation. Processes have already been put in place to mitigate these findings in the future through a tenured bonus structure. Additional review will be required to ensure any enrollment raises and bonuses are based upon the tenured bonus structure now in place.

Categories

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions

Other Findings in this Audit

  • 486102 2024-001
    Significant Deficiency Repeat
  • 486103 2024-001
    Significant Deficiency Repeat
  • 486104 2024-002
    Significant Deficiency
  • 486105 2024-002
    Significant Deficiency
  • 486106 2024-002
    Significant Deficiency
  • 486107 2024-002
    Significant Deficiency
  • 486108 2024-002
    Significant Deficiency
  • 1062544 2024-001
    Significant Deficiency Repeat
  • 1062545 2024-001
    Significant Deficiency Repeat
  • 1062546 2024-002
    Significant Deficiency
  • 1062547 2024-002
    Significant Deficiency
  • 1062548 2024-002
    Significant Deficiency
  • 1062549 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $46.79M
84.063 Federal Pell Grant Program $9.30M
84.033 Federal Work-Study Program $711,930
84.038 Federal Perkins Loan Program $390,611
84.047 Trio_upward Bound $324,079
84.044 Trio_talent Search $303,785
84.042 Trio_student Support Services $267,568
84.217 Trio_mcnair Post-Baccalaureate Achievement $252,949
84.007 Federal Supplemental Educational Opportunity Grants $242,767
81.049 Office of Science Financial Assistance Program $170,015
81.121 Nuclear Energy Research, Development and Demonstration $161,995
45.161 Promotion of the Humanities_research $24,895
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $7,544
45.310 Grants to States $438