Finding Text
Finding 2025-04 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Failure to Provide Student-Level Documentation to Support FISAP Reporting (significant deficiency) Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Criteria – Per 34 CFR § 668.24(a) (Recordkeeping Requirements), an institution must maintain and make available for review, records necessary to demonstrate compliance with the Title IV, HEA program requirements. This includes student-level records, such as ISIRs and related eligibility documentation, that support federal reporting, including data submitted on the FISAP. Condition – The College did not provide the requested student-level records (ISIRs) to substantiate the number of eligible applicants reported on the FISAP submitted to the U.S. Department of Education. As a result, we were unable to verify the accuracy and completeness of the eligible applicant data reported for the applicable award year. Subsequent to audit inquiry, the institution provided student-level documentation, including ISIRs, to support FISAP reporting. Upon review of the documentation provided, testing identified that one (1) out of seven (7) students included in one FISAP dependency/income grid did not align with the applicable dependency model based on their ISIRs. As a result, the institution updated its supporting records to address the identified misclassification within the tested grid. Cause – The condition appears to have resulted from inadequate record retention or retrieval practices for student-level documentation, lack of a defined process to respond to audit requests for FISAPsupporting documentation, and insufficient understanding of the requirement to retain and provide documentation supporting federal reporting. Effect – The accuracy and completeness of FISAP-reported eligible applicant data could not be verified, the College was not in compliance with Title IV recordkeeping requirements, and the inability to substantiate reported data increases the risk of Inaccurate federal reporting and program review findings. Questioned Costs – $0 Perspective – The FISAP is a certified federal report relied upon by the Department of Education to assess institutional participation and funding eligibility for Title IV programs. Failure to provide student-level documentation to support reported eligible applicants represents a systemic documentation and internal control deficiency, rather than an isolated oversight. Without access to ISIRs and related records, the College cannot demonstrate that FISAP-reported data are accurate, complete, or supported, which undermines the reliability of federal reporting. Repeat Finding – No Auditor’s Recommendation – We recommend that the College strengthen its record retention and documentation controls to ensure that all student-level records supporting data reported on the Fiscal Operations Report and Application to Participate (FISAP), including Institutional Student Information Records (ISIRs), are maintained, readily retrievable, and made available for audit and review purposes in accordance with federal recordkeeping requirements. Management’s Response – The institution acknowledges that this request was initially overlooked during the audit review. The requested sample testing of ISIRs has now been completed, and a total of 34 ISIR records have been provided and uploaded to the shared file for the auditor’s review. The institution respectfully requests a formal update to this finding (if applicable), once all submitted ISIR documents have been reviewed and deemed acceptable by the auditor. Responsible Officials - The Financial Aid Office under the direction of the Vice President of Student Affairs plans (to have the finding resolved by its next fiscal year end audit (between July – October 2026). The College is aware of the need to review and mitigate compliance risks in this area and will use the described corrective action plan to reduce those risks and eliminate the potential for future audit findings. View of Responsible Officials – The College agrees with the finding.