Finding 1221222 (2025-002)

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

AI Summary

  • Core Issue: The College failed to correct discrepancies in family size for 3 out of 12 students during the verification process, leading to noncompliance with federal verification requirements.
  • Impacted Requirements: The College did not follow 34 CFR 668.54(a) and related guidelines, which mandate accurate verification of applicant information and timely updates to Institutional Student Information Records (ISIR).
  • Recommended Follow-Up: Enhance staff training on verification processes, establish stronger internal controls, and implement a tracking system for timely ISIR corrections.

Finding Text

Finding No.: 2025-002 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: Special Tests and Provisions: Verification Questioned Costs: $20,042 Criteria: 34 CFR 668.54(a); FSA Handbook Application and Verification Guide, Chapter 4 requires an institution to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by ED. Institutions shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). A menu of potential verification items for each award year is published in the Federal Register, and the items to verify for a given application are selected by ED from that menu and indicated on the student’s output documents. Verification tracking groups and verification items for each award year can also be found in the annual FSA Handbook, Application and Verification Guide, Chapter 4. Institutions shall also require applicants to verify any information used to calculate an applicant’s Estimated Family Contribution (EFC) that the institution has reason to believe is inaccurate and provide an accurate code for the individual’s verification status in the Common Origination and Disbursement (COD) system. Condition: The following conditions were observed for 3 out of the 12 students tested out of a total of 25 students requiring verification during the fiscal year. The total amount awarded to these 3 students throughout the year was $20,042, whereas the total amount awarded to all 12 students tested was $83,491. Total amount awarded to all students selected for verification was $127,151. For 3 (or 25%) of 12 students tested, we noted discrepancies in family size between the verification worksheets and the students’ Institutional Student Information Records (ISIR), wherein the family size reflected on the verification worksheets was higher than that reported on the ISIR. Despite these discrepancies identified during the verification process, the ISIRs were not updated or corrected accordingly. Cause: The condition was due to the absence of adequate procedures and review controls to ensure that discrepancies identified during the verification process were properly updated and reflected in the ISIR and reported accurately in the COD system. Effect or potential effect: The College is in noncompliance with applicable verification requirements. Identification as a Repeat Finding: Finding No. 2024-004 Recommendation: The College should enhance training programs for staff involved in the verification process to ensure they are fully aware of the requirements and procedures. Establish robust internal controls and review mechanisms to ensure that verification worksheets are completed accurately and consistently with ISIRs. Implement a tracking system to ensure that all required corrections to ISIRs are performed in a timely manner. Views of responsible officials The College acknowledges the finding. Refer to corrective action plan.

Corrective Action Plan

Finding 2025-002: Special Tests and Provisions: Verification Recommendation: The College should enhance training programs for staff involved in the verification process to ensure they are fully aware of the requirements and procedures. Establish robust internal controls and review mechanisms to ensure that verification worksheets are completed accurately and consistently with ISIRs. Implement a tracking system to ensure that all required corrections to ISIRs are performed in a timely manner. Response: The College concurs with Finding 2025-002 and the auditors’ recommendation. To address this finding, the College has implemented the following actions. Action Responsible Party Target Date Status Reinstate mandatory two-tiered verification file review. No student file in any Verification Tracking Group may be finalized or disbursed without independent review and sign-off by the second FAO staff member. Review logs maintained and submitted monthly to FAO Director. FAO Director/VPEMSS 30 days In progress Implement ISIR Correction Tracking Log. Log captures: date discrepancy identified, date submitted to CPS, CPS confirmation number, and date corrected transaction received. FAO Director reviews weekly. This control directly addresses the gap that led to missed corrections in AY 2024-2025. FAO Director/Student Services Specialist IV 45 days In development Establish mid-year ISIR correction deadline. An internal institutional deadline – set 60 days before the award year closes – will be established to ensure all pending ISIR corrections are submitted before the CPS window closes. FAO Director responsible for tracking FAO Director 30 days Policy and procedure being drafted Mandatory annual FSA verification training for all FAO staff, covering tracking group identification, ISIR-worksheet cross-matching, CPS correction procedures, and the importance of submitting corrections before year-end closure. FAO Director 60 days Scheduled Conduct monthly internal file audits of verified student files. Results reported in writing to the VPEMSS. Shift from quarterly to monthly frequency to ensure errors are caught well before the award year closes. FAO Director 30 days First cycle initiated Revise and redistribute Verification SOP to all FAO staff across all campuses with mandatory sign-off. SOP to include explicit section on ISIR correction deadlines relative to award year closes. FAO Director 30 days In progress Recruit and fill three vacant FAO positions to restore full review capacity FAO Director/VPEMSS/HRO 90 days Recruitment initiated Primary Responsible Office: Director, Financial Aid Office Oversight Office: Vice President for Enrollment Management and Student Services Overall CAP Completion Target: Within 90 days of the final audit issuance

Categories

Special Tests & Provisions Student Financial Aid Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1221221 2025-001
    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