Finding Text
Finding 2024-010 - U.S. Department of Education (Title IV Student Financial Aid Programs - Missing Official Transfer Transcripts to Establish Title IV Eligibility (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 – Under Higher Education Act (HEA) § 484(d), a student must possess a high school diploma or its recognized equivalent, or meet an allowable alternative eligibility standard, to receive Title IV federal student aid. Per 34 CFR § 668.32(e), a student is eligible to receive Title IV funds only if the University has documentation showing that the student has a high school diploma or recognized equivalent, or has completed homeschooling, or meets the requirements for Ability-to-Benefit (ATB). Condition – During our review of student eligibility, we noted that one (1) out of sixty (60) sampled students was admitted to the College as transfer students, yet their files did not contain official transfer transcripts documenting completion of prior coursework or proof of meeting entrance requirements for the program in which they were enrolled. Despite the absence of required documentation, Title IV federal student aid was awarded and disbursed to these students. Cause –The College did not enforce its policy requiring receipt of official transfer transcripts prior to enrollment or awarding. Effect - Failure to reconcile may impact the University’s administrative capability under 34 CFR § 668.16. Title IV funds were disbursed to students without documentation of eligibility, creating questioned costs and liability for repayment to the Department of Education. Questioned Costs - $7,395 Perspective - Documentation of academic eligibility is a core compliance requirement. For transfer students, official transcripts confirm not only high school completion or recognized equivalents but also verify transfer credits and appropriate placement into programs. A 1.6% exception rate (1 out of 60 students) indicates a system-wide breakdown in Admissions/Financial Aid coordination, not an isolated oversight. Repeat Finding - Yes Auditor’s Recommendation - The University should require official transcripts prior to disbursement and strengthen record keeping controls. Management’s Response – Management has implemented standardized checklists and workflows, added secondary review, provided additional training to staff, and implemented periodic internal monitoring. View of Responsible Officials – Management agrees with the finding and acknowledges that official transfer transcripts were not consistently obtained or maintained to adequately document prior academic completion and establish Title IV eligibility in accordance with federal requirements.