Core Issue: The College's Student Verification Policy is missing key elements required by federal regulations.
Impacted Requirements: The policy lacks a timeframe for documentation submission, notification procedures for changes in financial aid, and a fraud referral process.
Recommended Follow-Up: Update the verification policy to include all required elements to ensure compliance and reduce risks of financial aid errors.
Finding Text
United States Department of Education
Federal Program: Student Financial Assistance Cluster
Reference Number: 2024-001
Federal Award Identifiers: P007A239034; P033A239034; P063P236291; P268K246291
Type of Finding: Non-Compliance and Significant Deficiency in Internal Control Compliance Requirement: Special Tests and Provisions – Verification
Condition: The College’s Student Verification Policy omitted following elements required by 34 CFR 668.53:
1. A defined timeframe for student applicants to submit requested verification documentation.
2. A policy for notifying applicants of changes to Expected Family Contribution (EFC) or financial assistance resulting from the verification process.
3. A policy for referring fraud cases to the Office of the Inspector General of the Department of Education.
Criteria: The College was required to incorporate all provisions of 34 CFR 668.53 into its written verification policies and procedures.
Cause: The College did not adopt the required elements in its written policies and procedures.
Effect: The absence of required written policies and procedures increased the risk of non-compliance with federal financial aid regulations, potentially leading to ineligible students receiving aid or delays in processing financial assistance.
Categories
Special Tests & ProvisionsEligibilitySignificant DeficiencyInternal Control / Segregation of Duties