Finding 1175763 (2025-004)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-27
Audit: 389674
Organization: Briar Cliff University (IA)

AI Summary

  • Core Issue: One student was found ineligible for the TEACH Grant due to GPA requirements not being met.
  • Impacted Requirements: Noncompliance with 34 CFR 686.11 regarding eligibility criteria for TEACH Grants.
  • Recommended Follow-Up: Implement policies and procedures to verify TEACH Grant eligibility before funds are distributed.

Finding Text

Program: Federal TEACH Grant CFDA Number 84.379 Federal Agency: U.S. Department of Education Federal Award Identification Number: Federal Award Year: June 30, 2024 Criteria: 34 CFR 686.11 states that for the purposes of the TEACH Grant program for an undergraduate student other than a student enrolled in a post-baccalaureate program, has not completed the requirements for a first baccalaureate degree; or for the purposes of a student in a first post-baccalaureate program, has not completed the requirements for a post-baccalaureate program; is enrolled in a TEACH Grant-eligible institution in a TEACH Grant-eligible program; is completing coursework and other requirements necessary to begin a career in teaching or plans to complete such coursework and requirements prior to graduating; and has (A) (1) A final cumulative secondary school grade point average (GPA) upon graduation of at least 3.25 on a 4.0 scale, or the numeric equivalent; or (2) A cumulative GPA of at least 3.25 on a 4.0 scale, or the numeric equivalent, based on courses taken at the institution through the most-recently completed payment period; (B) If the student is beyond the first year of a program of undergraduate education as determined by the institution, a cumulative undergraduate GPA of at least 3.25 on a 4.0 scale, or the numeric equivalent, through the most recently completed payment period; (C) If the student is a graduate student during the first payment period, a cumulative undergraduate GPA of at least 3.25 on a 4.0 scale, or the numeric equivalent; (D) If the student is a graduate student beyond the first payment period, a cumulative graduate GPA of at least 3.25 on a 4.0 scale, or the numeric equivalent, through the most-recently completed payment period; or (E) A score above the 75th percentile of scores achieved by all students taking the test during the period the student took the test on at least one of the batteries from a nationally-normed standardized undergraduate, graduate, or postbaccalaureate admissions test, except that such test may not include a placement test. Condition: For 1 student tested, the student was determined to be ineligible for the TEACH Grant, based on the student GPA and not exceeding the 75th percentile in one ACT area. Question Costs: Not applicable. Context: Noncompliance with federal regulations for 1 of 2 students who were tested for TEACH Grant eligibility. The student was determined to be ineligible for the TEACH Grant. The University distributed the funds to the student during the fiscal year under audit. Subsequent to year end the University returned those funds back to the Department of Education through the G5 portal. A total of 3 students were issued TEACH Grants by the University during fiscal year 2025. Effect: The accuracy of TEACH Grant eligibility is important in determining which students qualify for the grant and if they complete the grant agreement, will not have to pay back the grant. If the student becomes ineligible or changes their mind the grant can be turned into a direct loan. Cause: It does not appear that there are proper processes in place to verify eligibility for TEACH Grants before issuing the Grant to the student account. Recommendation: It is recommended that policies and procedures to verify TEACH Grant eligibility prior to distributing the Grant to a student.

Corrective Action Plan

Management’s Response: The University has undertaken several initiatives to enhance compliance and accuracy: Management acknowledges the material weakness related to the awarding and disbursement of TEACH Grants and recognizes the importance of ensuring that grant eligibility is verified in accordance with federal regulations prior to disbursement. During fiscal year 2025, an eligibility determination error was identified for one student. Subsequent to year-end, the University returned the related TEACH Grant funds to the U.S. Department of Education through the G5 system. Management has taken corrective actions to strengthen eligibility verification and prevent recurrence. Corrective actions implemented include: • Strengthened Leadership and Oversight: A new Financial Aid Director was hired in March 2025 and has prioritized the development and enforcement of appropriate controls over TEACH Grant awarding and disbursement. • Revised Policies and Procedures: TEACH Grant awarding and disbursement procedures were reviewed and updated to ensure alignment with federal eligibility requirements. • Improved Eligibility Documentation: The TEACH Grant application was enhanced to clearly document all required eligibility criteria and support consistent eligibility determinations. • Secondary Review Controls: A secondary review and approval process has been implemented to ensure that TEACH Grant eligibility is independently verified prior to awarding and disbursement. • Enhanced Tracking and Monitoring: Additional tracking mechanisms were implemented to confirm that eligibility requirements are met and documented before funds are applied to student accounts. • Ongoing Compliance Monitoring: The Financial Aid Office continues to monitor TEACH Grant activity to ensure continued compliance with program requirements. Management believes these actions have significantly strengthened internal controls over TEACH Grant awarding and disbursement. Continued application of these procedures is expected to prevent recurrence and support full compliance in future audit periods. These initiatives demonstrate the University’s commitment to maintaining accurate student enrollment records and ensuring compliance with federal regulations, thereby safeguarding the interests of its students and the institution.

Categories

Eligibility Student Financial Aid Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1175762 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $8.53M
84.063 FEDERAL PELL GRANT PROGRAM $1.32M
84.038 FEDERAL PERKINS LOAN PROGRAM $1.04M
84.044 TRIO TALENT SEARCH $551,485
84.042 TRIO STUDENT SUPPORT SERVICES $358,385
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $151,286
84.033 FEDERAL WORK-STUDY PROGRAM $81,461
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $9,430