Finding 2025-002 - Eligibility - Student Financial Assistance Cluster, ALN 84.268, June 30, 2025 Award Year, U.S. Department of Education Condition Calculation of Benefits: In addition to the requirements and limits, awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). The determination of need-based SFA award amounts is based on financial need. Non-need based SFA awards are not limited to financial need but cannot exceed the student’s COA. To determine non-need based SFA awards (unsubsidized aid) one would use the following formula – COA minus OFA. (November 2025 OMB Compliance Supplement pages 5-3-10 and 5-3-11) Out of forty students tested, two students were under-awarded both Subsidized and Unsubsidized loans and one student was under-awarded Subsidized loans. This was not a statistic. Corrective Actions To address the finding, loan certification procedures have been revised to include step-by-step procedures for determining loan eligibility. A standardized template has been created for calculating subsidized and unsubsidized loan amounts, with clear instructions that subsidized loans must be maximized before awarding unsubsidized loans. Comprehensive training on the calculation of loan eligibility has been provided for new staff, including subsidized versus unsubsidized loan rules, and one-on-one coaching is being provided for staff members with knowledge gaps. A quality assurance program that includes a random sample review of loan awards will be performed between the fall and winter semesters to identify errors and ensure that loans are being certified in accordance with applicable rules and limits. Reviews and findings will be documented so that errors can be addressed immediately. Responsible Official: Wendy G. Glass, Director of Student Financial Services Completion Date: December 4, 2025