Finding 1579 (2023-001)

Significant Deficiency
Requirement
E
Questioned Costs
$1
Year
2023
Accepted
2023-11-10
Audit: 2820
Auditor: Capincrouse LLP

AI Summary

  • Core Issue: The University disbursed federal financial aid to ineligible students, leading to questioned costs totaling $13,320.
  • Impacted Requirements: Violations of federal regulations for Direct Loans, TEACH Grants, and Pell Grants regarding eligibility criteria.
  • Recommended Follow-Up: Enhance reviews of student eligibility in the new financial aid system to prevent future disbursement errors.

Finding Text

Disbursements to Ineligible Students Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University disbursed various federal financial assistance to students who were not eligible for that aid under the code of federal regulations for the specific program. Criteria: Federal Direct Loans: 34 CFR 685.203(d) and (e); TEACH Grant: 34 CFR 686.11(a); Pell Grant: 34 CFR 690.6(a) and (b) Questioned Costs: $13,320 Context: For Federal Direct Loans, out of 60 students tested for Direct Loan eligibility, specifically, awarding Direct Loans within aggregate loan limits as outlined in 34 CFR 685.203(d) and (e), there was 1 student who was disbursed aid above their aggregate loan limit. This error caused questioned costs of $220. For TEACH grant, out of 3 students tested for TEACH grant eligibility, there was 1 student who was disbursed TEACH grant who was not eligible due to not meeting the minimum GPA requirements as established under 34 CFR 686.11(a). There were questioned costs of $1,886. For Pell grant, out of 30 students tested for Pell grant eligibility, there was 1 student who had a previous bachelor’s degree and was, therefore, ineligible for the Pell grant amounts disbursed based on 34 CFR 690.6(a). A total of $10,342 was disbursed as questioned costs. Additionally, out of 30 students tested for proper Pell Grant based on eligible coursework, there was 1 student who had aid disbursed for a course that was not eligible for Pell grant, based on 34 CFR 690.6(b). This error caused questioned costs of $872. The University corrected all of the above items during the audit and returned all necessary funds to Department of Education. Cause: During the 2022-2023 financial aid award year, the University implemented a new financial aid processing system that was being configured throughout the award year. Due to this change, the University was not able to maintain compliance with various student eligibility requirements. Effect: Students who were not eligible for aid received aid. The University was required to return funds for students who were not eligible. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University continue to assess areas for improvement in their new financial aid system and implement additional review over student eligibility before aid is disbursed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Disbursements to Ineligible Students Planned Corrective Action: While the Office of Financial Aid sought to replicate controls that were in place within the legacy system, the noted disbursements to ineligible students were a direct result of the system conversion to Workday. The following measures have been or will be taken to prevent such disbursements in the future. Transfer credit evaluation (prior degree and TEACH grant) To ensure students with prior bachelor’s degrees are not awarded incorrectly, the office will coordinate with the Registrar’s Office to ensure that all undergraduate students with a prior degree are flagged immediately after transcript evaluation. The transfer credit coordinator will notify the Office of Financial Aid. If the student’s ISIR does not reflect they have earned a prior bachelor’s degree the student will be notified and the ISIR will be corrected. Existing award programming prevents students with ISIRs indicating a prior degree from being awarded aid for which they are ineligible. To ensure transfer students with GPAs that do not meet the requirements to receive TEACH grant are not awarded incorrectly, the office will conduct a review of all transfer students awarded TEACH grant once all their transcripts have been received to ensure they meet transfer GPA eligibility requirements. Loans in excess of limits To ensure students are not awarded loans in excess of their aggregate limits, the financial aid operations department has begun to proactively review NSLDS data for any student that is seen to be approaching loan limits. When an ISIR indicates an eligibility amount that is less than a single year’s maximum award, the operations department reviews NSLDS and overrides aggregate totals as needed to ensure students are not awarded over their limits. We are going to work with our post-implementation consulting partner, Alchemy, to determine other best practices within Workday. Pell Grant awarded for courses that do not apply to student’s program of study To ensure students are not awarded Pell grant for courses that do not apply to their program of study, the office developed reports to compare the financial aid load used to calculate the award with the financial aid loan within the student’s program of study. While these reports were in use during the 2022-2023 award year, there were some academic programs that had to be updated because of issues with their initial setup. Those changes have abated in this second academic year, but the financial aid technician will conduct a final check in the last week of the 7A and 7B terms so any changes to program of study load status can be reevaluated. Person Responsible for Corrective Action Plan: Michael Sapienza, Associate Vice President of Enrollment Services Anticipated Date of Completion: Necessary reports and calculations will be developed prior to December 1, 2023. Review will continue on a continuous basis.

Categories

Questioned Costs Student Financial Aid Eligibility Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1580 2023-001
    Significant Deficiency
  • 1581 2023-001
    Significant Deficiency
  • 578021 2023-001
    Significant Deficiency
  • 578022 2023-001
    Significant Deficiency
  • 578023 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $22.11M
84.063 Federal Pell Grant Program $3.39M
84.038 Federal Perkins Loan Program $1.05M
84.425 Covid-19 Education Stabilization Fund Heerf - Institutional Portion $826,949
84.033 Federal Work-Study Program $180,248
84.007 Federal Supplemental Educational Opportunity Grants $98,195
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $39,606
84.425 Covid-19 Education Stabilization Fund Heerf - Student Aid Portion $-13,885