Finding Text
Finding 2024-001 Verification
Federal Agency: U.S. Department of Education
Program Name: Student Financial Assistance Cluster
Federal Direct Student Loans
Assistance Listing #: 84.268
Questioned Costs: None
Condition/Context
We reviewed the Seminary’s “Processes for Verifying Student’s Title IV Eligibility” policy. Our procedures revealed the following:
(1) The processes document does not list a time frame.
(2) The processes document does not list consequences for applicant's failure to provide requested documentation
within a specified time period.
(3) The processes document does not list how applicants may be notified regarding results of verification.
(4) The processes document does not list how corrections occur should they be found, only that the Financial Aid
Manager is responsible for accuracy.
(5) The processes document does not address 668.16(g) in regards to fraud or other criminal misconduct.
(6) The processes document lists a general ‘but not limited to” but not a full “clear” list.
(7) The processes document does not list the timeframe/deadlines and or consequences by CTS only that ED might
place a hold.
(8) The processes document does not list that CTS can exercise authority under 479(a).
Criteria
Per the Title 34, Code of Federal Regulations (CFR), Part 668 Subpart E, when a student’s Free Application for Federal Student Aid (FAFSA) is selected for verification purposes by the Secretary of the U.S. Department of Education, the student’s institution must verify all of the applicable items. This verification process must follow the institution’s published processes for verifying students’ Title IV eligibility that satisfy the provisions of Title 34, CFR, Section 668.51 through 668.61.
Cause
The Seminary’s Verification policy does not include enough appropriate language to satisfy the requirements of compliance with Title 34, CFR, Section 668.53.
Effect
The Seminary’s students and staff may not be aware of the necessary steps and time frames to complete Verification requests in accordance with Department of Education requirements. Thus, students may face consequences towards their financial aid that otherwise could have been mitigated.
Recommendation
The Seminary should update their process document to ensure that it includes clear steps that meet the compliance requirements.
Views of Responsible Officials
The Seminary will ensure process document is updated to be in compliance with the requirements of with Title 34, CFR, Section 668.53. In addition, the Seminary will consider the implementation of further controls ensure processes are in compliance.