Finding Text
Finding 2025-002 - U.S. Department of Education (ED), Student Financial Assistance Programs – Federal Work-Study Program (material weakness): Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Federal Teacher Education Assistance for College (TEACH), FAL No. 84.379, June 30, 2025 Criteria – Regardless of who employs the student, the institution is responsible for ensuring that the student is paid for work performed. 34 CFR 675.16. Condition – We are unable to verify the funds earned because five (5) of the six (6) students tested for Federal Work-Study Program payroll had missing and/or incomplete timesheets. Cause – The College did not properly review timesheets and either failed to obtain or misplaced timesheets documenting the hours worked to support compensation paid to students under the Federal Work-Study Program. One (1) student had a pay rate change but no documentation to support the change. Students worked when they were supposed to be in class. One (1) student signature & date is after starting date of employment. Effect – Students may have been over or underpaid compensation based on hours actually worked. Questioned Costs – $10,830. Perspective – This is considered a systemic problem given the five (5) exceptions noted from the sample of 6 students. Repeat Finding – Yes. Auditor's Recommendation – All timesheets should be reviewed and approved by the direct supervisor overseeing the student’s work before any Federal Work-Study wages are disbursed. Approved timesheets should then be systematically organized and securely retained to document compliance with federal requirements. Management’s Response – Tougaloo College acknowledges the findings identified in the audit regarding the Federal Work-Study (FWS) Program for the period ending June 30, 2025. We recognize the gravity of the "material weakness" designation and the systemic nature of the documentation exceptions noted. As the Vice President overseeing these services, I am committed to a rigorous overhaul of our FWS administrative protocols to ensure full compliance with 34 CFR 675.16. To address the root causes of these findings, the College is implementing the following measures immediately: • Mandatory Supervisor Training: All department heads and direct supervisors of FWS students must complete a mandatory compliance seminar. This training emphasizes that no student may be scheduled to work during designated class times and that no wages will be disbursed without a verified, contemporaneous timesheet. • Enhanced Timesheet Verification: We are transitioning to a standardized digital submission process. This system will require: o Verification of the student’s course schedule against hours worked to prevent overlap. o Electronic signatures from both the student and supervisor, timestamped to ensure they are captured prior to payroll processing. • Documentation and Record Retention: The Office of Financial Aid, in coordination with Payroll, will implement a "No Document, No Pay" policy. Documentation for any pay rate changes must now be uploaded and approved by the VP for Enrollment Management and Student Services before being reflected in the Jenzabar system. • Internal Monthly Audits: Starting next month, our internal compliance team will conduct random monthly spot-checks of FWS files (10% of active participants) to ensure all timesheets are present, complete, and accurately reflect hours worked. The College is currently reviewing the identified questioned costs of $10,830.00. We will work closely with the U.S. Department of Education to determine the appropriate restitution or adjustment required for any overpayments resulting from missing documentation. We are dedicated to rectifying these systemic issues and ensuring this does not remain a repeat finding in future audit cycles. Our goal is to maintain the highest level of integrity in our Title IV Student Financial Aid Programs. View of Responsible Officials – The College agrees with the finding.