Finding 1161263 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
$1
Year
2025
Accepted
2025-10-22
Audit: 371188
Organization: Milligan University (TN)

AI Summary

  • Core Issue: Students were paid for Federal Work Study hours during scheduled class times without valid exemptions, leading to improper payments.
  • Impacted Requirements: Compliance with the Federal Student Aid Handbook, which prohibits work during class unless properly documented exceptions are in place.
  • Recommended Follow-Up: Implement safeguards in software and training for supervisors to prevent and address these payment errors, ensuring compliance with federal regulations.

Finding Text

2025‐002 Significant Deficiency: Working During Scheduled Class Time (U.S. Department of Education - Federal Work Study Program, ALN #84.033) Criteria: In accordance with the 2024-2025 Federal Student Aid Handbook, in general, students are not permitted to work in Federal Work Study positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented. Statement of Condition: During the audit, it was noted that multiples students appear to have been paid for Federal Work Study hours logged and submitted for time the student was scheduled to be in class. The reasons for overlap vary, but no reasonable exemption could be verified. Questioned Costs: The known monetary error is an over-payment of $99. Extrapolation of the error across all students and pay periods that may have been affected estimates total possible monetary error of $3,115. Therefore, the monetary impact of this deficiency does not exceed the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 9 files for students participating in the Federal Work Study program during the 2024-2025 award year, and limited detail testing of an additional 22 students’ Federal Work Study documents pertaining to this specific attribute. For the 31 students tested, auditors vouched class schedules, timecards, and paystubs for two specific pay periods, one in each semester. Of these students for the specific pay periods tested, overlap between submitted work study hours paid and classes scheduled without reasonable exception was identified in the records for five students. Therefore, we consider the error rate as 16.13%. Cause and Effect: In certain cases of conflicting times, class took place as scheduled, but the student was not present, choosing to work instead; other cases appear to be related to students being present in class, but also clocked into their work study position, resulting in payment for hours not worked at all. In all instances, supervisors did not identify the conflicts when reviewing and submitting timesheets for payroll processing and funds were paid to the students for the overlapping times, which is prohibited without an adequate exemption that has been appropriately documented. Recommendation: The University should ensure that proper safeguards, in both software and personnel, are in place to prevent, identify, and remediate such errors to prevent over-payment of federal aid funds. View of Responsible Officials: The University concurs with the finding. The University provided a reminder via email to all students and supervisors each pay period throughout the year that students are not allowed to work during scheduled class times without documentation. Supervisor training was required of all FWS supervisors in August 2025 to emphasize the importance of compliance with this specific aspect of FWS as well as all other federal requirements governing the FWS program. Supervisors are expected to monitor when their students are beginning work and request documentation if clock-in, or any period of their work, falls within a scheduled class period.

Corrective Action Plan

Finding Reference Number: 2025-002 Working During Scheduled Class Time Summary of Finding: Students are not permitted to work in Federal Work Study positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community workstudy experience with exemptions being appropriately documented. The University had a few instances in which appropriate documentation for exemptions had not been obtained by the supervisors. The known error is $99 with extrapolation of the error across the population at $3,115. Entity’s Corrective Action Plan: The University understands the federal guidelines and provided reminders to all students and supervisors, via email, that students are not permitted to work during scheduled class times; the reminders were sent at the end of each pay period throughout the 2024-25 year. In August 2025, the University provided a required training session for all work study supervisors and reviewed the importance of compliance with this specific aspect of managing FWS as well as all other federal requirements governing the Federal Work Study Program. Supervisors and students continue to receive bi-monthly reminders of this policy. Supervisors are expected to monitor when their students are working and to know their students’ class schedules. They are expected to request documentation if clock-in times, or any period of their work shift, falls within a scheduled class time. Additionally, for 2025-26, the Human Resource Office is developing a review process to determine that appropriate documentation has been obtained if a student meets one of the eligible exemption criteria. Anticipated Completion Date: November 1, 2025 Name and Title of Responsible Person: Gus Morgan, Interim Financial Aid Director and VP for Enrollment Services and Rebecca Proffitt, Payroll and Student Employment Coordinator

Categories

Questioned Costs Student Financial Aid HUD Housing Programs Reporting Significant Deficiency

Other Findings in this Audit

  • 1161262 2025-001
    Material Weakness Repeat
  • 1161264 2025-001
    Material Weakness Repeat
  • 1161265 2025-001
    Material Weakness Repeat
  • 1161266 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $8.99M
84.063 FEDERAL PELL GRANT PROGRAM $1.44M
84.033 FEDERAL WORK-STUDY PROGRAM $143,690
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $93,290
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $36,807