Finding Text
Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grant Program ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 34 CFR 600.20, institutions must ensure that all eligible academic programs are properly reported and approved through the Eligibility and Certification Approval Report (ECAR) issued by the U.S. Department of Education. Institutions must maintain internal controls to verify that only eligible programs are included in Title IV aid processing. Condition - The institution does not have a process or controls in place for a timely review of program eligibility. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - No questioned costs, no ineligible programs identified. Identification of How Questioned Costs Were Computed - N/A Context - During the audit period, the School District did not perform verification over program eligibility of the programs offered. Of the 24 programs offered by the School District, all 24 programs met Title IV eligibility requirements. There was no documented process for reviewing ECAR updates or confirming program inclusion. Cause and Effect - The institution did not have a formal process for monitoring ECAR submissions and approvals. Responsibility for program eligibility verification was not clearly assigned and there was no oversight mechanism in place. Title IV funds could have been disbursed to students enrolled in programs not officially recognized on the institution’s ECAR, resulting in noncompliance with federal program eligibility requirements. This represents a material weakness in internal control over compliance. Recommendation - We recommend the institution implement a formal control structure to ensure all academic programs are reviewed for Title IV eligibility and included on the ECAR prior to disbursing aid. This should include assigning responsibility, establishing timelines for ECAR updates, and conducting periodic reconciliations between academic offerings and approved programs. Views of Responsible Officials and Planned Corrective Actions - The School District agrees with the finding. The School District is implementing a process to review academic programs for Title IV eligibility and ensure they are added to the ECAR before aid is awarded. This will include identifying who is responsible for updates and setting a regular schedule to review program listings so they stay accurate.