Finding 1241792 (2024-011)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2026-11-06
Audit: 415778
Organization: College of the Marshall Islands (MH)

AI Summary

  • Core Issue: The College failed to maintain necessary documentation for student eligibility under the Federal Pell Grant Program.
  • Impacted Requirements: Noncompliance with 34 CFR 668.24 regarding record-keeping for eligibility determination and retention of records for three years.
  • Recommended Follow-Up: Enhance internal controls to ensure proper documentation is retained for eligibility determinations and grant calculations.

Finding Text

Finding No.: 2024-011 - Eligibility Identification of the federal program: Federal Agency: U.S. Department of Education AL No. and Title: 84.063 Federal Pell Grant Program Federal Award No.: P063Q194572, P063Q204572, P063Q214572, P063Q224572, P063Q234572, P063P224572, P063P234572, P063P244572 Criteria or specific requirement (including statutory, regulatory or other citation): 34 CFR 668.24(c)(1)(iii) states “The records that an institution must maintain in order to comply with the provisions of this section include but are not limited to documentation of each student’s or parent borrower’s eligibility for title IV.” 34 CFR 668.24(e)(1) states “An institution shall keep records relating to its administration of the Federal Perkins Loan, FWS, FSEOG, Federal Pell Grant, ACG, National SMART Grant, or TEACH Grant Program for three years after the end of the award year for which the aid was awarded and disbursed under those programs.” Condition: No documentation was on file to support eligibility determination. Cause: The College lacks adequate internal control policies and procedures over eligibility, including retaining documentation to support eligibility determination and accurate calculation of grant award. Effect or potential effect: The College is in noncompliance with applicable eligibility requirements. Questioned costs: $8,070 Context: We identified 1,785 participants during the year with grant totaling $7,423,174. We tested 40 participants with grant totaling $171,609. The samples were statistically valid. For two (or 5%) participants with grant totaling $8,070, documentation that determines the student’s citizenship or expected family contribution was not on file. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The College management should improve internal control policies and strengthen controls over eligibility, specifically, retaining documentation to support eligibility determination and accurate calculation of grant award. Views of responsible officials: The College agrees with the finding and provides details in its Corrective Action Plan.

Corrective Action Plan

The College acknowledges the finding and has strengthened its management and internal controls over student eligibility and award accuracy by piloting the new Jenzabar Financial Aid (JFA) system during SY 2024–2025. The system is designed to improve eligibility verification, Pell Grant calculations, and maintenance of supporting documentation. Together with SONIS, JFA allows the Financial Aid Office to more efficiently review and cross-check student eligibility requirements, identify discrepancies, and ensure compliance with federal Title IV requirements.

Categories

Student Financial Aid

Other Findings in this Audit

  • 1241786 2024-005
    Material Weakness Repeat
  • 1241787 2024-006
    Material Weakness Repeat
  • 1241788 2024-007
    Material Weakness Repeat
  • 1241789 2024-008
    Material Weakness Repeat
  • 1241790 2024-009
    Material Weakness Repeat
  • 1241791 2024-010
    Material Weakness Repeat
  • 1241793 2024-012
    Material Weakness Repeat
  • 1241794 2024-013
    Material Weakness Repeat
  • 1241795 2024-014
    Material Weakness Repeat
  • 1241796 2024-015
    Material Weakness Repeat
  • 1241797 2024-016
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $7.42M
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $2.20M
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $721,598
84.047 TRIO UPWARD BOUND $237,825
10.308 RESIDENT INSTRUCTION, AGRICULTURE, AND FOOD SCIENCE FACILITIES AND EQUIPMENT GRANTS $26,277
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $12,552
84.425 EDUCATION STABILIZATION FUND $2,100