Finding 1221221 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-06-29
Audit: 405580
Organization: College of Micronesia - Fsm (FM)

AI Summary

  • Core Issue: The College awarded FSEOG amounts that exceeded $4,000 and fell below $100, violating federal limits.
  • Impacted Requirements: Noncompliance with 34 CFR 676.20 regarding minimum and maximum FSEOG awards.
  • Recommended Follow-Up: Implement formal policies, provide training for staff, and conduct regular reviews to ensure compliance.

Finding Text

Finding No.: 2025-001 Federal Agency: U.S. Department of Education AL Program: 84.063/84.033/84.007 Student Financial Assistance Cluster Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Eligibility Questioned Costs: None Criteria: 2 CFR 200.303 (a) states the recipient and subrecipient of federal awards must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The College is required to establish internal control to ensure compliance with the following requirements: 34 CFR 676.20 (s) states that: Minimum and maximum Federal Supplemental Educational Opportunity Grants (FSEOG) awards requires: (a) An institution may award an FSEOG for an academic year in an amount it determines a student needs to continue his or her studies. However, except as provided in paragraph (c) of this section, an FSEOG may not be awarded for a full academic year that is— (1) Less than $100; or (2) More than $4,000. Condition: We noted that seven students were awarded amounts exceeding the maximum allowable limit of $4,000, while one student received an award below the minimum allowable amount of $100. Cause: The condition was primarily due to the College’s limited familiarity with FSEOG requirements, as this represents its first year administering the program. As a result, management did not have adequate procedures or guidance in place to ensure compliance with the minimum and maximum award limits prescribed under federal regulations. Effect or potential effect: The College is in noncompliance with applicable requirements. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management establish and implement formal policies and procedures for the administration of the FSEOG program, including clear guidance on the minimum and maximum award limits in accordance with federal regulations. Management should also provide adequate training to Financial Aid Office personnel on applicable federal requirements, perform supervisory reviews of award calculations prior to disbursement, and conduct periodic monitoring to ensure ongoing compliance with established limits. Views of responsible officials The College acknowledges the finding. Refer to corrective action plan.

Corrective Action Plan

Finding 2025-001: Eligibility Recommendation: We recommend that management establish and implement formal policies and procedures for the administration of the FSEOG program, including clear guidance on the minimum and maximum award limits in accordance with federal regulations. Management should also provide adequate training to Financial Aid Office personnel on applicable federal requirements, perform supervisory reviews of award calculations prior to disbursement, and conduct periodic monitoring to ensure ongoing compliance with established limits. Response: The College acknowledges the findings resulting from the initial year of the Federal Supplemental Educational Opportunity Grant (FSEOG) program's implementation. The College recognizes that the finding resulted from deficiencies in newly implemented award procedures during the first year of the FSEOG program. In light of this, we wish to provide context regarding the situation and the corrective actions undertaken to address the issue. The seven students identified in this finding were awarded FSEOG funds that reflected their significant financial need and the institution's commitment to enabling students to cover both direct and indirect enrollment costs. An internal review conducted by the Financial Aid Office revealed that these awards inadvertently exceeded the $4,000 annual maximum established by program regulations. Following this internal review, prompt corrective measures were enacted, culminating in the issuance of a formal memorandum to the Comptroller in October of FY26. This memorandum directed adjustments to the affected students’ FSEOG awards to ensure compliance with the prescribed annual maximum. This internal monitoring process underscores the College’s proactive commitment to program integrity and fiscal accountability. Furthermore, the unexpended funds were returned to the U.S. Department of Education during FY26. The College remains dedicated to the proper administration of the FSEOG program and has reinforced its internal review procedures. This includes conducting more frequent audits of award ceilings during active disbursement periods to prevent similar errors in future award years. To address the finding, the College will implement the following actions: 1. Establishment of Formal Policy and Standard Operating Procedures (SOPs): Within 30 days, the College will adopt and implement a dedicated section within the Financial Aid Policy and Procedures Manual specifically for the FSEOG program. This document will delineate federal award limitations, selection criteria based on exceptional financial need groupings, and compliance parameters in accordance with 34 CFR 676.20. 2. Staff Training and Competency Review: Prior to the next award cycle, the College will conduct a mandatory training workshop for all counselors and processing staff within the Financial Aid Office. This training will emphasize the identification of the FSEOG-eligible student population, the applicable selection criteria, and the importance of cross-referencing final award packages. 3. Monitoring and Long-Term Quality Control: The College will implement a mandatory two-tiered verification process. Prior to any FSEOG batch disbursement being sent to the Office of the Comptroller for final payment execution, a senior financial aid officer or director must review and authorize a compliance checklist. This checklist will confirm that there are no boundary violations, and any batch disbursement package containing an amount below $100 or exceeding $4,000 per academic year will be flagged for review. Quarterly compliance reviews will be documented and retained as part of the College's internal control records to verify continued compliance with FSEOG award requirements and to provide supporting documentation for future audits. Primary Responsible Office: Director, Financial Aid Office Oversight Office: Vice President for Enrollment Management and Student Services Overall CAP Completion Target: Addressed in Dec 2026

Categories

Student Financial Aid Subrecipient Monitoring Eligibility

Other Findings in this Audit

  • 1221222 2025-002
    Material Weakness Repeat
  • 1221223 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $9.77M
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $4.02M
84.425 EDUCATION STABILIZATION FUND $1.41M
10.511 SMITH-LEVER EXTENSION FUNDING $968,436
10.203 PAYMENTS TO AGRICULTURAL EXPERIMENT STATIONS UNDER THE HATCH ACT $773,628
84.047 TRIO UPWARD BOUND $639,518
84.044 TRIO TALENT SEARCH $383,939
93.236 GRANTS TO STATES TO SUPPORT ORAL HEALTH WORKFORCE ACTIVITIES $240,401
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $225,412
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $207,825
84.033 FEDERAL WORK-STUDY PROGRAM $167,402
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $161,685
93.107 AREA HEALTH EDUCATION CENTERS $94,658
10.514 EXPANDED FOOD AND NUTRITION EDUCATION PROGRAM $57,004
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $9,500
10.308 RESIDENT INSTRUCTION, AGRICULTURE, AND FOOD SCIENCE FACILITIES AND EQUIPMENT GRANTS $7,680