Finding 1191462 (2025-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-03-27
Audit: 395393
Organization: Montcalm Community College (MI)

AI Summary

  • Core Issue: An ineligible student received Title IV funding despite failing to show academic improvement after an appeal.
  • Impacted Requirements: Compliance with the Satisfactory Academic Progress (SAP) policy as mandated by Title 34 CFR 668.34.
  • Recommended Follow-Up: Establish a formal review process to ensure students demonstrate required academic progress before receiving further Title IV funding.

Finding Text

Ineligible Student Received Title IV funding Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A242049, P033A242049, P063P241644, P063Q241644 and P268K251644. Criteria. Title 34 of the Code of Federal Regulations (34 CFR 668.34) requires institutions to establish and apply a reasonable Satisfactory Academic Progress (SAP) policy to determine whether an otherwise eligible student is making sufficient academic progress to continue receiving Title IV, HEA program assistance. Condition. During our testing, we noted that a student successfully appealed their academic dismissal in the Summer 2022–2023 semester. The student did not receive Title IV funding during that term and subsequently failed both attempted courses. Despite the lack of demonstrated academic improvement following the appeal, the student was awarded Title IV funding in the Spring 2024–2025 semester based on the appeal granted during the 2022–2023 academic year. Cause. A review was not performed to determine whether the prior appeal remained valid or whether the student had demonstrated sufficient academic progress to qualify for Title IV aid in the Spring 2024–2025 semester. Effect. As a result of this condition, one student received Title IV funding that who was not eligible based on the criteria outlined in the College's satisfactory academic policy (SAP). Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Recommendation. We recommend the College implement a formal review process to verify that students who were previously dismissed and granted an appeal in a prior academic year have demonstrated the required academic improvement before receiving subsequent Title IV funding, or alternatively, obtain a new appeal determination. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.

Corrective Action Plan

Ineligible Student Received Title IV Funding Auditor Description of Condition and Effect. During our testing, we noted that a student successfully appealed their academic dismissal in the Summer 2022–2023 semester. The student did not receive Title IV funding during that term and subsequently failed both attempted courses. Despite the lack of demonstrated academic improvement following the appeal, the student was awarded Title IV funding in the Spring 2024–2025 semester based on the appeal granted during the 2022–2023 academic year. As a result of this condition, one student received Title IV funding that who was not eligible based on the criteria outlined in the College's satisfactory academic policy (SAP). Auditor Recommendation. We recommend the College implement a formal review process to verify that students who were previously dismissed and granted an appeal in a prior academic year have demonstrated the required academic improvement before receiving subsequent Title IV funding, or alternatively, obtain a new appeal determination. Corrective Action. Management acknowledges this finding and is implementing strengthened Satisfactory Academic Progress (SAP) review procedures to ensure students who previously appealed an academic dismissal are properly evaluated before receiving Title IV funding. The Financial Aid Office is now working closely with the Registrar to ensure both Title‑IV and non‑Title‑IV students undergo appropriate SAP monitoring. Information Technology is developing a report that identifies students by financial‑aid track status, allowing Financial Aid to review aid‑receiving students while the Registrar evaluates all others. Students who require SAP follow‑up are contacted by the appropriate office, and SAP appeal forms are reviewed under updated criteria to ensure students demonstrate academic improvement before additional aid is awarded. These steps ensure the College remains compliant with federal SAP requirements and prevents ineligible students from receiving Title IV funds. Responsible Person. Jennifer Stimson, Director of Financial Aid Anticipated Completion Date. June 30, 2026

Categories

Eligibility Student Financial Aid Reporting Significant Deficiency

Other Findings in this Audit

  • 1191458 2025-002
    Material Weakness Repeat
  • 1191459 2025-002
    Material Weakness Repeat
  • 1191460 2025-002
    Material Weakness Repeat
  • 1191461 2025-002
    Material Weakness Repeat
  • 1191463 2025-003
    Material Weakness Repeat
  • 1191464 2025-003
    Material Weakness Repeat
  • 1191465 2025-003
    Material Weakness Repeat
  • 1191466 2025-003
    Material Weakness Repeat
  • 1191467 2025-003
    Material Weakness Repeat
  • 1191468 2025-004
    Material Weakness Repeat
  • 1191469 2025-004
    Material Weakness Repeat
  • 1191470 2025-004
    Material Weakness Repeat
  • 1191471 2025-004
    Material Weakness Repeat
  • 1191472 2025-004
    Material Weakness Repeat
  • 1191473 2025-005
    Material Weakness Repeat
  • 1191474 2025-005
    Material Weakness Repeat
  • 1191475 2025-005
    Material Weakness Repeat
  • 1191476 2025-005
    Material Weakness Repeat
  • 1191477 2025-005
    Material Weakness Repeat
  • 1191478 2025-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $943,515
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $265,248
17.268 H-1B JOB TRAINING GRANTS $123,598
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $114,209
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $61,793
84.033 FEDERAL WORK-STUDY PROGRAM $29,396
84.063 FEDERAL PELL GRANT PROGRAM $3,405