Finding Text
Finding 2024-007 - U.S. Department of Education (Title IV Student Financial Aid Programs - Inconsistent Cost of Attendance (COA) Budgets (material weakness): Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2024; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2024; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2024; Federal Work-Study Program, FAL No. 84.033, June 30, 2024. Criteria – Per 34 CFR § 668.16(f), institutions must ensure that policies and procedures are administered consistently and that all required student eligibility and financial aid determinations are made accurately. Per 34 CFR § 668.2 and § 668.72, institutions must use COA components that are reasonable, compliant with statutory definitions, and applied consistently to all students within similar categories. The Federal Student Aid Handbook, Volume 3 - Calculating Awards, further requires institutions to apply the cost of attendance components uniformly to students in the same category and maintain documentation supporting all COA amounts used in packaging. Condition – During testing of student financial aid files, we noted that while the College provided official cost of attendance (COA) budgets, twelve (12) out of sixty (60) students tested had COA budgets that were not consistent with the COA budgets approved and published by the University. Cause – The inconsistencies appear to have resulted, in part, from the University not updating its cost of attendance budget tables within the student information system or did not communicate COA updates across departments leading to outdated or incorrect COA components being applied during packaging. Effect - Inconsistent COA application indicates weaknesses in the University’s internal controls and may affect its compliance with the administrative capability requirements under 34 CFR § 668.16. Questioned Costs - $0 Perspective – COA inconsistencies weaken the accuracy of all aid calculations and raise concerns regarding the school’s overall financial aid administration and quality assurance processes. Repeat Finding - No Auditor’s Recommendation - Implement a formal process ensuring COA components are applied consistently for all students within the same category Management’s Response – Management is working to implement standardized workflows and periodic internal monitoring. The University has also enhanced system controls. View of Responsible Officials – Management agrees with the finding and acknowledges that Cost of Attendance budgets were not applied consistently across similarly situated students. The University recognizes the importance of uniform COA application and adequate documentation to ensure accurate financial aid determinations and compliance with federal regulations and is committed to implementing corrective measures to address this issue.