Finding 1169430 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-01-16

AI Summary

  • Core Issue: Students were paid for Federal Work Study hours during scheduled class times without proper documentation of exemptions.
  • Impacted Requirements: Federal guidelines prohibit working during class unless specific conditions are met and documented.
  • Recommended Follow-Up: Implement safeguards in both software and personnel to prevent and identify such 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 multiple students appear to have been paid for Federal Work Study hours logged and submitted for time the student was scheduled to be in class without verification of reasonable exemption. Questioned Costs: The known monetary error is an over‐payment of $23. Extrapolation of the error across all students and pay periods that may have been affected estimates total possible monetary error of $7,149. 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 5 files for students participating in the Federal Work Study program during the 2024‐2025 award year, and limited detail testing of an additional 6 students’ Federal Work Study documents pertaining to this specific attribute. For the 11 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 2 students. Therefore, we consider the error rate as 18.18%. Cause and Effect: In one case of conflicting times, the student’s professor could not verify whether there had been changes to their regularly scheduled class time to vouch for reasonable exemption for an allowable overlap in time; in the second case, the student manually entered their time for submission, mistakenly overlapping with the beginning of their scheduled class for multiple days during their first week employed. In both 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: Management concurs with the auditor’s finding. Due to incomplete documentation of reasonable exemptions, students were paid Federal Work Study funds for time worked during regularly scheduled class meeting times. Corrective action has been implemented to ensure such conflicts are prevented in the future.

Corrective Action Plan

2025-002 Significant Deficiency: Working During Scheduled Class Time (U.S. Department of Education - Federal Work Study Program, ALN #84.033) The University noted that multiple students appear to have been paid for Federal Work Study hours logged and submitted for time the student was scheduled to be in class without verification of a reasonable exemption. Management Response Management concurs with the auditor’s finding. Due to incomplete documentation of reasonable exemptions, students were paid Federal Work Study funds for time worked during regularly scheduled class meeting times. Responsible Person(s) Alex Campbell, Director of Financial Aid, and Bobbi Farris, Manager for Student Employment, are the responsible parties for the corrective action. Corrective Action Plan Upon identifying deficiencies related to the lack of documentation for allowable exemptions, the University immediately communicated with all Student Employment Supervisors regarding permitted exemptions and required documentation for students to work during scheduled class times. These requirements and exemptions are reviewed and agreed upon during the annual Student Employment Supervisor Trainings, which occur prior to job postings. Students are notified of the documentation required to be exempt and eligible to work during a scheduled class time during the onboarding process. In collaboration with Information Technology and third-party consultants, the Student Employment Office is enhancing reporting functions to ensure accurate identification of students with conflicting work and class times and to flag any conflicting entries for review and resolution prior to approval. These reports will be reviewed each pay period to ensure accurate documentation is obtained for any conflicting times flagged. While these fields are being implemented, regulations related to working during scheduled class times have been reinforced with both students and supervisors. Beginning with the Spring 2026 term, the University will implement a new policy prohibiting students participating in the Federal Work Study Program from working during scheduled class times, regardless of any met exemptions. All Student Employment Supervisors will be notified of this updated policy by the end of the Fall 2025 term. Training will continue on an annual basis to ensure proper procedures are followed by Student Employment Supervisors and students participating in the Federal Work Study Program. The Director of Financial Aid and Manager for Student Employment will review student time records each pay period to ensure full compliance with these policies. Expected Completion Date This corrective action plan was implemented in September 2025, during the Fall 2025 term. Final implementation will occur at the start of the Spring 2026 term.

Categories

Student Financial Aid Reporting Significant Deficiency

Other Findings in this Audit

  • 1169429 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $121.65M
84.063 FEDERAL PELL GRANT PROGRAM $37.09M
84.033 FEDERAL WORK-STUDY PROGRAM $692,750
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $341,796
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $254,063