Finding 1175305 (2025-007)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-02-25
Audit: 389014
Organization: Hilbert College (NY)

AI Summary

  • Core Issue: The College over-awarded a student $360 in Pell Grants due to using an incorrect Student Aid Index (SAI) instead of the SAI from the Institutional Student Information Record (ISIR).
  • Impacted Requirements: Compliance with 34 CFR 690.61, which mandates accurate disbursement data based on valid SAR or ISIR submissions.
  • Recommended Follow-Up: The College should revise its procedures to ensure that the correct SAI is used from the ISIR for Pell award calculations.

Finding Text

2025–007 Pell Award Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063 Federal Award Identification Number and Year: P268K251853; 2025 Award Period: June 1, 2024 – May 31, 2025 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 690.61 states that: § 690.61 Submission process and deadline for a Student Aid Report or Institutional Student Information Record. (a) Submission process. (1) Except as provided in paragraph (a)(2) of this section, an institution must disburse a Federal Pell Grant to an eligible student who is otherwise qualified to receive that disbursement and electronically transmit Federal Pell Grant disbursement data to the Secretary for that student if— (i) The student submits a valid SAR to the institution; or (ii) The institution obtains a valid ISIR for the student. (2) In determining a student's eligibility to receive his or her Federal Pell Grant, an institution is entitled to assume that SAR information or ISIR information is accurate and complete except under the conditions set forth in 34 CFR 668.16(f) and 668.60. (b) Valid Student Aid Report or Valid Institutional Student Information Record deadline. Except as provided in the verification provisions of § 668.60 and the late disbursement provisions of § 668.164(g) of this chapter, for a student to receive a Federal Pell Grant for an award year, the student must submit the relevant parts of the valid SAR to his or her institution or the institution must obtain a valid ISIR by the earlier of— (1) The last date that the student is still enrolled and eligible for payment at that institution; or (2) By the deadline date established by the Secretary through publication of a notice in the Federal Register. § 690.62 Calculation of a Federal Pell Grant. (a) The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year. (b) (1) (i) For a confined or incarcerated individual enrolled in an eligible prison education program, no Federal Pell Grant may exceed the cost of attendance (as defined in section 472 of the HEA) at the institution that student attends. (ii) If an institution determines that the amount of a Federal Pell Grant for that student exceeds the cost of attendance for that year, the amount of the Federal Pell Grant must be reduced until the Federal Pell Grant does not exceed the cost of attendance at such institution and does not result in a title IV credit balance under 34 CFR 668.164(h). Condition/Context: During our testing, it was noted that the student's student aid index (SAI) recorded in the College's system did not match the student's SAI per their ISIR. Since the College did not use the ISIR SAI to determine the student's Pell award for the 2024-2025 academic year, the College ultimately over-awarded the student $360 in Pell. Questioned costs: $360 Cause: During our testing, it was noted a student was over-awarded Pell due to the College using the incorrect SAI for the student. Effect: Inaccurate Pell amount awarded to student which could lead to compliance issues with regulations. Repeat Finding: No. Recommendation: We recommend that the College review its procedures to ensure their internal system pulls the correct SAI amounts directly from the student's ISIR when calculating a student’s Pell award. Views of responsible officials: Please refer to the attached corrective action plan.

Corrective Action Plan

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063 Recommendation: We recommend that the College review its procedures to ensure their internal system pulls the correct SAI amounts directly from the student's ISIR when calculating a student’s Pell award. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To ensure compliance, the College will implement the following corrective actions: 1. System Configuration Review: The Financial Aid Office, in coordination with Powerfaids (College Board), will conduct a comprehensive review of system configuration settings to confirm that SAI values are pulled directly and accurately from the student’s valid ISIR transaction when calculating Pell eligibility when PARM ROLL is run each year. 2. Validation and Testing: The College will perform test file reviews comparing ISIR SAI values to system-calculated Pell awards to confirm accuracy. Any discrepancies identified will be corrected through system reconfiguration or vendor-supported adjustments (as per College Board.) 3. Quality Control Review: A secondary-level review, (i.e., the counselors designated to their individual alphabet cohort) will be implemented during each awarding cycle to confirm that Pell awards align with the student’s valid SAI and enrollment intensity. These corrective actions strengthen internal controls over Pell awarding, ensure SAI data integrity, and mitigate the risk of future calculation discrepancies. Name(s) of the contact person(s) responsible for corrective action: Stephanie Schroeder, Director of Financial Aid Planned completion date for corrective action plan: Immediate action will take place, with the goal of implementing these changes effectively before the start of the new academic year

Categories

Student Financial Aid Eligibility Significant Deficiency

Other Findings in this Audit

  • 1175275 2025-001
    Material Weakness Repeat
  • 1175276 2025-001
    Material Weakness Repeat
  • 1175277 2025-001
    Material Weakness Repeat
  • 1175278 2025-001
    Material Weakness Repeat
  • 1175279 2025-001
    Material Weakness Repeat
  • 1175280 2025-002
    Material Weakness Repeat
  • 1175281 2025-002
    Material Weakness Repeat
  • 1175282 2025-002
    Material Weakness Repeat
  • 1175283 2025-002
    Material Weakness Repeat
  • 1175284 2025-002
    Material Weakness Repeat
  • 1175285 2025-003
    Material Weakness Repeat
  • 1175286 2025-003
    Material Weakness Repeat
  • 1175287 2025-003
    Material Weakness Repeat
  • 1175288 2025-003
    Material Weakness Repeat
  • 1175289 2025-003
    Material Weakness Repeat
  • 1175290 2025-004
    Material Weakness Repeat
  • 1175291 2025-004
    Material Weakness Repeat
  • 1175292 2025-004
    Material Weakness Repeat
  • 1175293 2025-004
    Material Weakness Repeat
  • 1175294 2025-004
    Material Weakness Repeat
  • 1175295 2025-005
    Material Weakness Repeat
  • 1175296 2025-005
    Material Weakness Repeat
  • 1175297 2025-005
    Material Weakness Repeat
  • 1175298 2025-005
    Material Weakness Repeat
  • 1175299 2025-005
    Material Weakness Repeat
  • 1175300 2025-006
    Material Weakness Repeat
  • 1175301 2025-006
    Material Weakness Repeat
  • 1175302 2025-006
    Material Weakness Repeat
  • 1175303 2025-006
    Material Weakness Repeat
  • 1175304 2025-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $7.57M
84.063 FEDERAL PELL GRANT PROGRAM $3.41M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $71,019
84.033 FEDERAL WORK-STUDY PROGRAM $67,144
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $22,266