Recommendation: We recommend that the University establish procedures to ensure that at least 7% of Federal Work Study allocation is used for community service jobs, including a reading tutor, or successfully receive a waiver. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: National University (NU) agrees with the importance of ensuring compliance with FWS community service requirements. The University implemented additional internal controls and policy changes to how it administers the FWS program and completes FISAP reporting to resolve this issue. During NU’s annual FISAP reporting process, it discovered that it had not met its FWS community service obligation. The University submitted a waiver, but it was denied. The University took immediate action to determine the cause of not meeting its FWS community service obligations. Community Partnership Management: National University previously had a partnership with Barrio Logan College Institute (BLCI) located in San Diego, CA. This partnership changed during the pandemic when all schools received a waiver for the community service requirement. In August 2024, Elyse Joiner, Director of Financial Aid Processing, again reached out to BLCI to reestablish a partnership. At that time, National was informed that the previous point of contact was no longer employed with BLCI, but the institute was still interested in partnering with National to meet the community service requirement for Federal Work Study. Ms. Joiner had several communications with BLCI to implement and finalize the setup of the reading and math tutors, with the only outstanding item related to the need for a virtual option. Unfortunately, communication between National University and BLCI ceased in April 2025 when National stopped receiving responses from BLCI to its inquiries. To establish another partnership, Ms. Joiner reached out to United Way of San Diego County to explore the possibility of establishing a reading or math tutor program with them but did not receive a response. Program Administration Change: Federal Work Study funds were budgeted to meet the University’s community service requirement; however, due to unforeseen circumstances and the efforts noted above, the University was unable to meet the 7% community service requirement. The University did have tutors available to the University community, but this did not fulfill the community service requirement. National University has since rectified this for the current aid year. The positions have been posted (R 2025 3051), and the University will have multiple FWS students at the Nest at Spectrum, offering tutoring services to both NU students and the public. The YMCA next to Spectrum will also be informed about the services to promote additional awareness within the local community. Additional opportunities are being actively explored within the Student Disability Services team and the Schools of Law & Public Service and Education. Steps taken to improve transparency and tracking: The University conducted a holistic review of the current FWS policies and procedures and has or will take the following steps: o Comprehensive training for administering the FWS program and Campus-Based Funding programs o Develop and implement an internal control plan that monitors FWS spending activity, allowing for the proactive identification of when the University should reallocate funds between campus-based programs. o Implemented quarterly calibration meetings between FWS/Operations leaders and HR to ensure its FWS program is on track to meet the FWS community service, literacy, and tutoring regulatory requirements. o Explore the expansion of community service relationships and opportunities within the Federal Work Study Program. Name(s) of the contact person(s) responsible for corrective action: - Alan Coddington, AVP Student Financial Services - Elyse Joiner, Director of Operations, Financial Aid Processing and Technical Solutions - Rob Conlon, AVP Financial Aid Compliance Planned completion date for corrective action plan: February 2026