Finding Text
2025-006 – Eligibility – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work Study, Federal Supplemental Educational Opportunity Grant Federal Award Number: P063P242403, P268K232403, P033A244364, P007A244364 Award Year: 2024-25, 2023-24 Criteria – Institutions are required to determine student eligibility for some Title IV programs who have financial need known as “need-based” programs. The total aid that a student receives from need-based programs may not exceed the student’s financial need. For other Title IV programs, eligibility is based on the student’s expected family contribution. Institutions are required to have controls in place to support the eligibility of each student for need and non-need based programs. Condition/context – We selected a sample of 41 students out of a population of 742 students who received Title IV aid during the year. Of the 41 samples selected we found the following errors with student’s eligibility for need and non-need based programs: • 2 students appeared to receive Pell disbursements that were less than their eligible award. The University was unable to support the amount of Pell award calculated. • 2 students received adjustments reducing their budgeted cost of attendance in error that was not identified by the University • 4 students in our sample did not receive their refund disbursements within the required timeframe due to administrative processing errors. • 6 students had one or more elements of their budgeted cost of attendance that did not tie to the approved cost of attendance schedule. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None Cause/effect – This occurred because of turnover in the student financial assistance office and a lack of properly documented and implemented control policies and procedures to ensure accurate determination and application of student aid eligibility. Repeat finding – Yes, 2024-007 Recommendation – We recommend the University implement the proper controls to ensure the determination of student eligibility for Title IV aid is appropriate and supported. Views of responsible officials and planned corrective actions – Heritage University agrees with the recommendation and is strengthening its processes and internal controls surrounding the determination and documentation of student eligibility for Title IV aid.