Finding Text
Federal Agency: U.S. Department of Education
Pass-through Entity: None
Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.’s 84.007, 84.033,
84.038, 84.063, 84.268, 84.379)
Requirement: Eligibility and Special Tests and Provisions
Criteria:
In accordance with 2 CFR 200.303, the College must establish and maintain effective internal control over the Federal
awards to provide reasonable assurance the College is in compliance with Federal statutes, regulations, and terms
and conditions of the Federal award. The College must have systems in place that provide reasonable assurance that
the information is accurate, allowable, and in compliance with the terms and conditions of the grant agreement.
Volume 4 of the Federal Student Aid Handbook states a school must ensure that its administrative procedures for the
FSA programs include an adequate system of internal controls. Effective internal control systems ensure the College is
meeting its fiduciary responsibilities related to Title IV funds.
Condition:
Overrides for special circumstance requests and income verifications can be performed by any individual with access to the College’s financial aid packaging software without prior approval.
Cause of Condition:
An internal control over electronic data processing for software security is missing.
Effect:
Unauthorized overrides to student eligibility and income, which would affect the level of a student’s award.
Questioned Costs:
No questioned costs.
Perspective Information:
N/A
Recommendation:
Volume 4 of the Federal Student Aid Handbook states that electronic data processing controls should be in place to only allow individuals with special security classifications to make changes to the programs that determine student need and awards. The system should also be able to identify the individuals who make such changes. Due to the smaller size of the College and limited staff and resources, it is not feasible for the College to restrict security access. Thus, we recommend a review system be put in place prior to the entry of system overrides in the software system to ensure the override is properly authorized.
Views of Responsible Official(s):
The College implemented a policy where all special circumstance requests and income verification overrides must be reviewed by a second staff member effective September 2023. The second staff member reviews each override, either approves or denies the paperwork, then signs and dates the paperwork. The paperwork is returned to the first staff member to make the changes in PowerFAIDS. The responsible college official is Tina Wiseman, Director of Financial Aid. See Corrective Action Plan.