Finding 1210657 (2024-016)

Material Weakness Repeat Finding
Requirement
CELN
Questioned Costs
-
Year
2024
Accepted
2026-04-28

AI Summary

  • Core Issue: A student received a summer Pell Grant without meeting eligibility criteria, indicating a failure in the review process.
  • Impacted Requirements: Compliance with federal regulations for Pell Grant disbursement, specifically regarding summer enrollment and eligibility verification.
  • Recommended Follow-Up: Strengthen awarding procedures and enhance supervisory reviews to ensure all eligibility criteria are met before disbursing funds.

Finding Text

Finding 2024-016 - U.S. Department of Education (Title IV Student Financial Aid Programs - Pell Grant Disbursed Without Meeting Summer Eligibility Requirements (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 HEA 401 (c), A Pell Grant may be awarded for additional terms within the same award year only if the student is enrolled at least half-time and is eligible for payment for additional coursework beyond the student’s annual award amount. Institutions must ensure the student meets all summer Pell eligibility criteria before disbursing additional Pell funds. Condition – During testing of Pell Grant disbursements, we identified that one (1) out of sixty (60) students received a summer Pell Grant even though the student did not meet the federal eligibility criteria for a summer disbursement under Year-Round Pell provisions. The student did not meet the required enrollment or acceleration requirements but was nevertheless awarded and disbursed Pell funds for the summer term. Cause – The exception occurred due to lack of review to confirm Pell eligibility before awarding funds, and misinterpretation or misapplication of year-round Pell rules. Effect - The University disbursed Pell funds to a student who did not qualify, resulting in $793.00 in questioned costs. Disbursing Pell funds without verifying eligibility places the University out of compliance with federal requirements. Improper Pell disbursements may lead to required fund repayment, program review findings, and administrative capability concerns under 34 CFR § 668.16. Questioned Costs - $793 Perspective – Although this exception occurred for only one student, summer Pell awarding errors are treated seriously because they involve strict eligibility criteria and Year-Round Pell provisions, which are closely monitored by the Department of Education. Even a single error indicates a potential weakness in the school’s summer awarding review process and a need for stronger eligibility verification controls. Repeat Finding - No Auditor’s Recommendation - The University should update and strengthen its Pell Grant awarding and review procedures to align with current Pell Grant regulations and enrollmentintensity– based awarding requirements. The University should also enhance supervisory review for summer awarding. Management’s Response – Management has added secondary review, implemented periodic internal monitoring, and conducted targeted staff training tied to updated procedures. View of Responsible Officials – Management agrees with the finding and acknowledges that Pell Grant funds were disbursed for summer enrollment without consistently ensuring and documenting that all federal summer eligibility requirements were met prior to disbursement.

Corrective Action Plan

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-016 1. Finding Summary The auditor determined that Pell Grant funds were disbursed for summer enrollment without adequate documentation demonstrating that students met all required summer Pell eligibility criteria. As a result, the institution could not demonstrate compliance with federal requirements governing the award and disbursement of additional Pell Grant funds for summer terms. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that Pell Grant funds were disbursed for summer enrollment without consistently ensuring and documenting that all federal summer eligibility requirements were met prior to disbursement. 3. Root Cause Analysis The root cause of this finding resulted from insufficient supervisory review of summer Pell eligibility determinations and gaps in staff training regarding federal requirements for awarding and disbursing additional Pell Grant funds for summer enrollment. 4. Corrective Action(s) Management has added secondary review, implemented periodic internal monitoring, and conducted targeted staff training tied to updated procedures. Description of Corrective Actions The institution has added a required supervisory or secondary review to confirm summer Pell eligibility prior to processing or disbursement, implemented periodic internal monitoring and quality assurance reviews to verify ongoing compliance, and conducted targeted staff training aligned with updated summer Pell eligibility procedures. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions reduce the risk of improperly awarding or disbursing Pell Grant funds for summer enrollment by strengthening supervisory oversight, improving staff understanding of summer eligibility requirements, and ensuring eligibility is reviewed and verified prior to disbursement. Ongoing monitoring and quality assurance reviews provide additional safeguards to identify and prevent future noncompliance. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Director of Financial Aid • Name (optional): 7. Implementation Timeline • Corrective action implemented: Yes (No) • If not fully implemented, expected completion date: June 30, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) Fully implemented Partially implemented (Not yet implemented) Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability Ongoing supervisory review and periodic internal monitoring will be conducted to ensure summer Pell eligibility requirements are consistently met and documented prior to disbursement. Continued staff training, standardized review procedures, and quality assurance checks will be maintained to support long-term compliance and timely identification and correction of any eligibility issues.

Categories

Student Financial Aid Subrecipient Monitoring Eligibility Material Weakness

Other Findings in this Audit

  • 1210606 2024-004
    Material Weakness Repeat
  • 1210607 2024-004
    Material Weakness Repeat
  • 1210608 2024-004
    Material Weakness Repeat
  • 1210609 2024-004
    Material Weakness Repeat
  • 1210610 2024-005
    Material Weakness Repeat
  • 1210611 2024-005
    Material Weakness Repeat
  • 1210612 2024-005
    Material Weakness Repeat
  • 1210613 2024-005
    Material Weakness Repeat
  • 1210614 2024-006
    Material Weakness Repeat
  • 1210615 2024-006
    Material Weakness Repeat
  • 1210616 2024-006
    Material Weakness Repeat
  • 1210617 2024-006
    Material Weakness Repeat
  • 1210618 2024-007
    Material Weakness Repeat
  • 1210619 2024-007
    Material Weakness Repeat
  • 1210620 2024-007
    Material Weakness Repeat
  • 1210621 2024-007
    Material Weakness Repeat
  • 1210622 2024-008
    Material Weakness Repeat
  • 1210623 2024-008
    Material Weakness Repeat
  • 1210624 2024-008
    Material Weakness Repeat
  • 1210625 2024-008
    Material Weakness Repeat
  • 1210626 2024-009
    Material Weakness Repeat
  • 1210627 2024-009
    Material Weakness Repeat
  • 1210628 2024-009
    Material Weakness Repeat
  • 1210629 2024-009
    Material Weakness Repeat
  • 1210630 2024-010
    Material Weakness Repeat
  • 1210631 2024-010
    Material Weakness Repeat
  • 1210632 2024-010
    Material Weakness Repeat
  • 1210633 2024-010
    Material Weakness Repeat
  • 1210634 2024-011
    Material Weakness Repeat
  • 1210635 2024-011
    Material Weakness Repeat
  • 1210636 2024-011
    Material Weakness Repeat
  • 1210637 2024-011
    Material Weakness Repeat
  • 1210638 2024-012
    Material Weakness Repeat
  • 1210639 2024-012
    Material Weakness Repeat
  • 1210640 2024-012
    Material Weakness Repeat
  • 1210641 2024-012
    Material Weakness Repeat
  • 1210642 2024-013
    Material Weakness Repeat
  • 1210643 2024-013
    Material Weakness Repeat
  • 1210644 2024-013
    Material Weakness Repeat
  • 1210645 2024-013
    Material Weakness Repeat
  • 1210646 2024-014
    Material Weakness Repeat
  • 1210647 2024-014
    Material Weakness Repeat
  • 1210648 2024-014
    Material Weakness Repeat
  • 1210649 2024-014
    Material Weakness Repeat
  • 1210650 2024-015
    Material Weakness Repeat
  • 1210651 2024-015
    Material Weakness Repeat
  • 1210652 2024-015
    Material Weakness Repeat
  • 1210653 2024-015
    Material Weakness Repeat
  • 1210654 2024-016
    Material Weakness Repeat
  • 1210655 2024-016
    Material Weakness Repeat
  • 1210656 2024-016
    Material Weakness Repeat
  • 1210658 2024-017
    Material Weakness Repeat
  • 1210659 2024-017
    Material Weakness Repeat
  • 1210660 2024-017
    Material Weakness Repeat
  • 1210661 2024-017
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $4.86M
84.063 FEDERAL PELL GRANT PROGRAM $3.98M
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $1.28M
84.031 HIGHER EDUCATION_INSTITUTIONAL AID $640,518
93.658 FOSTER CARE_TITLE IV-E $222,374
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $146,410
84.184 SAFE AND DRUG-FREE SCHOOLS AND COMMUNITIES_NATIONAL PROGRAMS $97,937
47.076 EDUCATION AND HUMAN RESOURCES $49,977
93.307 MINORITY HEALTH AND HEALTH DISPARITIES RESEARCH $34,071
84.033 FEDERAL WORK-STUDY PROGRAM $21,362
12.903 GENCYBER GRANTS PROGRAM $16,783
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $15,000
47.083 INTEGRATIVE ACTIVITIES $3,631