Finding Text
Finding 2024-014 - U.S. Department of Education (Title IV Student Financial Aid Programs - Inaccurate Recipient Counts Reported on the FISAP (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 § 668.14 (b)(19) – Program Participation Agreement (PPA), institutions must accurately report to the Secretary information that the Secretary requires for participation in any Title IV, HEA program. Per 34 CFR § 690.83 (a), institutions must report annually to the Secretary the total number of students receiving Pell Grants and the distribution of those recipients by income category and ensure the report is complete and accurate. Inaccurate reporting violates federal reporting requirements and the institution’s Program Participation Agreement (PPA). Condition – During testing of the Fiscal Operations Report and Application to Participate (FISAP), we compared the number of recipients reported in selected income categories to the income information contained in the ISIRs reviewed. We found that the counts reported on the FISAP did not match the ISIR data, resulting in inaccurate reporting of Pell Grant recipients across certain income ranges. Cause – The inaccuracies appear to have resulted from failure to reconcile ISIR income information to the summary totals reported on the FISAP, use of incorrect or incomplete datasets when preparing recipient counts, and insufficient supervisory review over the FISAP reporting process. Effect - The Department of Education may receive incorrect statistical and demographic reporting used for policymaking and funding formulas, the University is not in compliance with federal reporting requirements and its Program Participation Agreement, and there are also an increased risk of administrative capability concerns under 34 CFR § 668.16. Questioned Costs - $0 Perspective – Accurate reporting of Pell Grant recipients by income category is essential because ED uses these data for national policy purposes, campus-based funding allocations, and program monitoring. Discrepancies between FISAP reported totals and ISIR data indicate a systemic reporting weakness, rather than a clerical oversight, and demonstrate the need for stronger data validation and reconciliation procedures. Repeat Finding - No Auditor’s Recommendation - The University should strengthen review and approval controls and improve data validation processes by ensuring that datasets used for FISAP preparation are complete, consistent, and aligned with financial aid records. Management’s Response – Management has added secondary review, implemented periodic internal monitoring, and added system configuration limitations. View of Responsible Officials – Management agrees with the finding and acknowledges that recipient counts reported on the FISAP were not consistently accurate in accordance with federal reporting requirements.