Finding 1173185 (2024-004)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2026-02-10
Audit: 386639
Organization: College of Micronesia - Fsm (FM)

AI Summary

  • Core Issue: The College failed to follow proper verification procedures for financial aid applications, leading to noncompliance with federal requirements.
  • Impacted Requirements: Verification processes outlined in 34 CFR 668.54(a) and the FSA Handbook were not adhered to, resulting in incorrect verification methods and missing documentation.
  • Recommended Follow-Up: Enhance staff training, establish stronger internal controls, and implement a tracking system for timely corrections to ensure compliance with verification requirements.

Finding Text

Federal Agency: U.S. Department of Education AL Program: Student Financial Assistance Cluster - 84.063 Federal Pell Grant Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Special Tests and Provisions: Verification Questioned Costs: $53,441 Criteria: 34 CFR 668.54(a); FSA Handbook Application and Verification Guide, Chapter 4 requires an institution to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by ED. Institutions shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). A menu of potential verification items for each award year is published in the Federal Register, and the items to verify for a given application are selected by ED from that menu items for each award year can also be found in the annual FSA Handbook, Application and Verification Guide, Chapter 4. Institutions shall also require applicants to verify any information institution has reason to believe is inaccurate and Condition: For 6 (or 19%) of 31 students tested, incorrect verification procedures were performed by the College. Standard verification (V1) was performed instead of the required custom verification (V4). , whereas V4 requires verification their statement of education purpose. For 1 (or 3%) of 31 students tested, verification worksheet is missing and required verification procedure is not performed. For 5 (or 16%) of 31 students tested, discrepancies were found in the verification worksheet versus . For 3 (or 10%) of 31 students tested, corrections required for ISIRs were not made. Cause: The College did not effectively monitor compliance with applicable verification requirements. Effect: The College is in noncompliance with applicable verification requirements. Recommendation: The College should enhance training programs for staff involved in the verification process to ensure they are fully aware of the requirements and procedures. Establish robust internal controls and review mechanisms to ensure that verification worksheets are completed accurately and consistently with ISIRs. Implement a tracking system to ensure that all required corrections to ISIRs are performed in a timely manner. Views of responsible officials The College acknowledges the finding. Refer to their corrective action plan.

Corrective Action Plan

Finding No.: 2024-04 - Special Test and Provisions: Verification Recommendation The College should enhance training programs for staff involved in the verification process to ensure they are fully aware of the requirements and procedures. Establish robust internal controls and review mechanisms to ensure that verification worksheets are completed accurately and consistently with ISIRs. Implement a tracking system to ensure that all required corrections to ISIRs are performed in a timely manner. Response The College acknowledges the audit finding regarding verification errors, including the incorrect application of verification tracking groups, missing documentation, discrepancies between verification worksheets and ISIRs, and failure to make required corrections. In response, the Financial Aid Office (FAO) is committed to strengthening its verification procedures to ensure full compliance with federal regulations and to protect the integrity of Title IV funds. To this end, the College will implement the following corrective actions: 1. Policy and Procedure Enhancement a. The FAO will develop and implement a formal Standard Operating Procedure (SOP) for the verification process, revise and update all existing verification worksheet forms. This SOP will include: • Clear guidelines for identifying and applying the correct verification tracking groups (e.g.,Vl,V4,V5). • Procedures for resolving discrepancies between verification worksheets and ISIRs prior to award disbursement. • Steps for submitting timely and accurate ISIR corrections, as required. • A documentation checklist to ensure all required verification forms and statements of educational purpose are collected and properly stored. 2. Policy and Procedure Enhancement a. To ensure consistent understanding and application of federal verification rules, FAO staff across all campuses will: • Complete mandatory annual training sessions on verification policies, ISIR review, and regularly read updates on the Federal Student Aid (FSA) Knowledge Center. • Participate in internal refresher workshops focused on hands-on case processing and error prevention. • Complete relevant modules from the Federal Student Aid (FSA) training site, including those on verification tracking groups and identity verification requirements. 3. Verification Quality Control Protocol a. The FAO will implement a structured quality control protocol for verification, including: • A two-person verification review system in which one staff member processes the file and another independently reviews it for accuracy and completeness. • Use of a standardized review checklist to ensure all required documents match the ISIR and that any discrepancies are properly resolved and documented. • A log of all verification actions, including corrections submitted to FAFSA Processing System (FPS) and updates made in the student’s file, to support audit readiness. 4. Oversight and Accountability a. The Director of the Financial Aid Office (FAO) will be responsible for overseeing verification compliance and ensuring corrective actions are implemented effectively. This includes: • Monitoring the accuracy of verification tracking group assignments and documentation across all campuses. • Tracking the completion of required training for all FAO staff. • Conducting quarterly file audits to verify ongoing compliance with federal verification standards. • Reporting findings and corrective actions quarterly to the VPEMSS). Contact: VPEMSS Completion Date - September 30, 2025

Categories

Student Financial Aid Special Tests & Provisions

Other Findings in this Audit

  • 1173184 2024-003
    Material Weakness Repeat
  • 1173186 2024-005
    Material Weakness Repeat
  • 1173187 2024-006
    Material Weakness Repeat
  • 1173188 2024-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $9.89M
84.425 EDUCATION STABILIZATION FUND $2.83M
10.511 SMITH-LEVER EXTENSION FUNDING $932,221
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $878,978
84.047 TRIO UPWARD BOUND $674,250
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $538,601
10.203 PAYMENTS TO AGRICULTURAL EXPERIMENT STATIONS UNDER THE HATCH ACT $452,084
84.044 TRIO TALENT SEARCH $401,721
93.236 GRANTS TO STATES TO SUPPORT ORAL HEALTH WORKFORCE ACTIVITIES $374,944
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $255,649
10.308 RESIDENT INSTRUCTION, AGRICULTURE, AND FOOD SCIENCE FACILITIES AND EQUIPMENT GRANTS $93,039
10.514 EXPANDED FOOD AND NUTRITION EDUCATION PROGRAM $57,525
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $30,149