Finding Text
Finding 2025-010 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Failure to Document High School Completion for Title IV Eligibility (Significant Deficiency): Information on the federal program – Federal Direct Student Loans, ALN 84.268, June 30, 2025; Federal Pell Grant Program, ALN 84.063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, ALN 84.007, June 30, 2025; Federal Work-Study Program, ALN 84.033, June 30, 2025. Criteria – Under Higher Education Act (HEA) § 484(d), a student must possess a high school diploma or its recognized equivalent, or meet an allowable alternative eligibility standard, to receive Title IV federal student aid. Per 34 CFR § 668.32(e), a student is eligible to receive Title IV funds only if the institution has documentation showing that the student has a high school diploma or recognized equivalent, or has completed homeschooling, or meets the requirements for Ability-to-Benefit (ATB). Condition – During testing of student eligibility, we noted that one (1) out of sixty (60) sampled students did not have documentation of high school completion or its recognized equivalent (e.g., high school transcript, diploma, or GED certificate) in their student files. Despite the absence of proof of high school completion, the student was enrolled and awarded Title IV federal student aid. Cause – The exception appears to have resulted from failure to collect or retain required documentation at the time of admission or prior to awarding aid and lack of a systematic verification checkpoint to confirm high school completion before packaging Title IV awards. Effect – Noncompliance may impact the University’s administrative capability under 34 CFR § 668.16, exposing the University to inaccurate reporting and potential repayment liability. Questioned Costs - $12,895 Auditor’s Perspective – Of the 60 students selected for testing, 1 student, or 1.67% of the sample, did not have sufficient documentation to demonstrate completion of high school or its recognized equivalent. The absence of required documentation prevents the institution from demonstrating that the student's Title IV eligibility was adequately supported prior to the disbursement of federal student aid. Repeat Finding – Yes Auditor’s Recommendation – The University should implement a mandatory eligibility verification process and strengthen document collection and retention controls. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.