Finding 1228300 (2025-004)

Material Weakness Repeat Finding
Requirement
A
Questioned Costs
-
Year
2025
Accepted
2026-08-28

AI Summary

  • Core Issue: Three students (7.5%) were found working during scheduled class hours, violating federal regulations regarding FWS employment.
  • Impacted Requirements: Noncompliance with 34 CFR 675.20 regarding allowed work hours and the need for accurate timesheets.
  • Recommended Follow-Up: Review and update policies to prevent compensation for hours worked during class times and ensure accurate tracking of hours worked.

Finding Text

Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is…”, Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be - … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.” Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 7 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented. “You must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle (i.e., twice a month, every week, every two weeks, etc., but not less than once a month). These amounts and hours recorded must match the hours for which the student is paid.” Condition: During our testing of forty individuals receiving federal work study, we noted three individuals (7.5%) working during scheduled class hours. We consider this condition to be an instance of noncompliance relating to the Activities Allowed or Unallowed compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2024-008. Statistical sampling was not used in making sample selections. Questioned Costs: $854 Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations. Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours or for hours not actually worked. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

Corrective Action Plan

Condition: During our testing of forty individuals receiving federal work study, we noted three individuals (7.5%) working during scheduled class hours. We consider this condition to be an instance of noncompliance relating to the Activit ies Allowed or Unallowed compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2024-008. Statistical sampling was not used in making sample selections. Corrective Action Plan The Work Office acknowledges the finding regarding students working during scheduled class hours and recogn izes this as a repeat finding from the prior audit period (2024-008). In response, the Work Office has implemented enhanced internal contro ls and strengthened oversight processes. These actions include: • formalized procedures prohibiting students from working during schedu led class times without prior documented class cancellation • implementation of a centralized class cancellation tracking log • enhanced payroll review processes and • expanded training for students, supervisors, and faculty Additionally, monitoring activities have been increased through routine payroll reviews and ongoing coordi nation between the Work Office and Provost Office The Work Office believes these corrective actions appropriately address the root cause of the finding and has established controls designed to ensure compliance with federal requirements and prevent recurrence in future audit periods. Clear expectations and documentation requirements have been established and communicated across campus. Process Improvement The Work Office, in coordination with the Provost Office, has strengthened procedures to ensure students are not permitted to work during scheduled class times. A formal process has been implemented requiring verification and documentation of any class cancellation prior to a student working during a scheduled class period. A centra lized class cancellation tracking log has been established and is jo intly maintained by the Work Office and Provost Office to ensure consistency and oversight. Staff Training The Dean of Work and Provost have enhanced tra ining and communication efforts to ensure all stakeholders understand compliance requirements. • Students: Informed through monthly department meetings and electronic communication that they are prohibited from working during scheduled class times. • Student Supervisors/Managers: Reinforce policies and monitor student work schedules. • Faculty: Continuously notified by the Provost of their responsibility to report class cancel lations to both the Provost Office and Work Office. • Supervisors: Receive ongoing training through monthly Supervisor Training sessions, including compliance requirements, payroll accuracy and review of payroll reports prior to submission, and maintenance of documentation standards and tracking logs. Documentation procedures are available in a shared drive accessible to supervisors. The Work Office and Provost Office will dedicate time to educating and reminding students and faculty that students are not allowed to work during schedu led class time, and how to report a cancelled class. The Work Office wi ll dedicate time to double-checking the student payrol l reports before sending them to Human Resources. System and Manual Controls • The Work Office has implemented additional internal controls designed to prevent and detect noncompliance, including • Secondary review of al l student payroll reports by the Work Office prior to submission to Human Resources • Verification of student work hours against class schedules • Requirement that students submit documentation (facu lty email or Learning Management System announcement) prior to working during a cancelled class time • Maintenance of a centralized exception log for all approved class cancellations Monitoring and Compliance Ongoing monitoring procedures have been established to ensure continued compliance, including: • Regular payroll reviews conducted by the Dean of Work • Coordination between the Work Office and Provost Office to verify reported class cancel lations ensures faculty compliance with class cancellation reporting requirements • Monthly Supervisor Training to reinforce compliance expectations by routine oversight activities that provide continuous reinforcement of institutional and federal requirements. • Continuous communication to students, supervisors, and faculty regard ing pol icy requirements Responsible Person(s) for Correction Action Plan: Leslie Johnson, Dean of Work - Responsible for student education, payroll review, and prevention of overpayments Laura Wiedlocher, Provost - Responsible for faculty communication and enforcement of class cancellation reporting Student Supervisors/Managers - Responsible for reinforcing policies and monitoring student compliance Implementation Date for Corrective Action Plan: Corrective actions were implemented throughout the 2024-2025 academic year and will continue on an ongoing basis.

Categories

Student Financial Aid

Other Findings in this Audit

  • 1228282 2025-002
    Material Weakness Repeat
  • 1228283 2025-003
    Material Weakness Repeat
  • 1228284 2025-004
    Material Weakness Repeat
  • 1228285 2025-005
    Material Weakness Repeat
  • 1228286 2025-002
    Material Weakness Repeat
  • 1228287 2025-003
    Material Weakness Repeat
  • 1228288 2025-004
    Material Weakness Repeat
  • 1228289 2025-005
    Material Weakness Repeat
  • 1228290 2025-002
    Material Weakness Repeat
  • 1228291 2025-003
    Material Weakness Repeat
  • 1228292 2025-004
    Material Weakness Repeat
  • 1228293 2025-005
    Material Weakness Repeat
  • 1228294 2025-002
    Material Weakness Repeat
  • 1228295 2025-003
    Material Weakness Repeat
  • 1228296 2025-004
    Material Weakness Repeat
  • 1228297 2025-005
    Material Weakness Repeat
  • 1228298 2025-002
    Material Weakness Repeat
  • 1228299 2025-003
    Material Weakness Repeat
  • 1228301 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $2.46M
84.063 FEDERAL PELL GRANT PROGRAM $1.46M
84.033 FEDERAL WORK-STUDY PROGRAM $901,487
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $28,762
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $16,000