Finding 1241794 (2024-013)

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

AI Summary

  • Core Issue: The College's policies for verifying FAFSA information are incomplete and do not meet federal requirements.
  • Impacted Requirements: Key verification procedures outlined in 34 CFR 668.53 and 668.54(a) are missing, leading to noncompliance.
  • Recommended Follow-Up: Management should update the Student Financial Aid Policy and Procedures Manual to include all necessary verification provisions.

Finding Text

Finding No.: 2024-013 - Special Tests and Provisions – Verification 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 668.53 states that: (a) An institution must establish and use written policies and procedures for verifying an applicant’s Free Application for Federal Student Aid (FAFSA) information in accordance with the provisions of this subpart. These policies and procedures must include: (1) The time period within which an applicant must provide any documentation requested by the institution in accordance with 34 CFR 668.57; (2) The consequences of an applicant’s failure to provide the requested documentation within the specified time period; (3) The method by which the institution notifies an applicant of the results of its verification if, as a result of verification, the applicant’s Expected Family Contribution (EFC) changes and results in a change in the amount of the applicant’s assistance under the title IV, HEA programs; (4) The procedures the institution will follow itself or the procedures the institution will require an applicant to follow to correct FAFSA information determined to be in error; and (5) The procedures for making referrals under 34 CFR 668.16(g). (b) An institution’s procedures must provide that it will furnish, in a timely manner, to each applicant whose FAFSA information is selected for verification a clear explanation of: (1) The documentation needed to satisfy the verification requirements; and (2) The applicant’s responsibilities with respect to the verification of FAFSA information, including the deadlines for completing any actions required under this subpart and the consequences of failing to complete any required action. (c) An institution’s procedures must provide that an applicant whose FAFSA information is selected for verification is required to complete verification before the institution exercises any authority under section 479A(a) of the HEA to make changes to the applicant’s cost of attendance or to the values of the data items required to calculate the EFC. 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 information required for the Verification Tracking Group to which the applicant is assigned. Condition: The College’s policies and procedures for verifying an applicant’s FAFSA information do not include all of the requirements identified in the Criteria above. Cause: The College lacks internal control over periodic review of policies and procedures related to verifying an applicant’s FAFSA information, to ensure all required provisions stated in the Criteria above are covered. Effect or potential effect: The College is in noncompliance with applicable special tests and provisions for verification requirements. Questioned costs: Not applicable. Context: Due to the nature of the finding, we are unable to quantify the extent of noncompliance. We reviewed the Student Financial Aid Policy and Procedures Manual for Academic Years 2023-2024 and 2024-2025 and noted that not all the requirements identified in the Criteria above are covered. Identification as a repeat finding, if applicable: 2023-015 Recommendation: College management should revisit its Student Financial Aid Policy and Procedures Manual and ensure all required provisions stated in the Criteria above are covered. 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. During FY2025, the College reviewed and updated the relevant sections of its Financial Aid Policies and Procedures Manual to address the identified deficiencies and incorporate the applicable federal verification requirements under 34 CFR 668.53 and 668.54. These updates strengthen the College's internal controls over FAFSA verification and ensure that required verification procedures are properly documented. The College will continue to review and monitor its policies and procedures to maintain compliance with federal Title IV requirements and prevent recurrence of the finding.

Categories

Student Financial Aid Special Tests & Provisions

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
  • 1241792 2024-011
    Material Weakness Repeat
  • 1241793 2024-012
    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