Finding 370500 (2023-001)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-02-26
Audit: 292086
Organization: Goddard College Corporation (VT)

AI Summary

  • Core Issue: The College is non-compliant with Uniform Guidance due to a student-employee not maintaining satisfactory academic progress and lacking proper notification.
  • Impacted Requirements: Failure to adhere to established SAP standards and inadequate segregation of duties in the registrar's office.
  • Recommended Follow-Up: Implement automated alerts for SAP deviations, provide training for financial aid staff, and ensure proper segregation of duties to prevent conflicts of interest.

Finding Text

Condition: As of the audit period ending June 30, 2023, the College was found to be in non-compliance with the Uniform Guidance (2 CFR 200, Subpart E, Section 200.90). A student (1 of 40 tested) failed to maintain satisfactory academic progress (SAP), was not provided a notice of a probationary period. It was noted that this student was also an employee of the College and proper segregation of duties did not exist. Context: The College has established SAP standards, including credit completion requirements, as outlined in its published financial aid policies. These standards are in accordance with the Uniform Guidance requirements for administering federal financial aid. In addition, the employee in the registrar's office was also the student in question. Cause: The student in question is a member of the registrar’s office, causing a potential conflict of interest or lack of segregation of duties. Effect or Potential Effect: Student did not receive notice of the probationary period. Questioned Costs: None noted. Recommendations: The College should ensure those in the registrars office are not able to award themselves credit. Implement Automated Alerts: Explore the implementation of automated systems to generate alerts when a student's academic progress deviates from the SAP standards, facilitating prompt intervention. Training for Financial Aid Staff: Provide additional training for financial aid staff to ensure a comprehensive understanding of SAP regulations and the importance of strict adherence. Segregation of Duties: The College should establish adequate segregation of duties to ensure a member of the registrar’s office is not also the individual responsible to review their own SAP status.

Corrective Action Plan

The College has controls and processes in place to properly evaluate credit (SAP). As part of the corrective action we have documented and re-trained the Registrar and financial aid staff on the process to record SAP; notify the student of probationary periods; and notify financial aid of a change in SAP status. The process has an additional section that establishes segregation of duties such that a member of the Registrar’s office shall not update their own record but would request posting be reviewed and completed by another member of the registrar’s office. The documentation of this process is included below: 1. At the beginning of each semester the Registrar’s office will evaluate credit (SAP) on the prior semester. In order to ensure proper segregation of duties the following section has been added. • If a member of the Registrar’s office is a student during the prior semester a different member of the Registrar’s office will evaluate their SAP and update their record. • Any notification related to the evaluation of SAP will be conducted by the other Registrar’s office member. 2. The Registrar’s office will notify financial aid of students without credit. • The Financial Aid Office will provide appropriate notifications for students who did not receive credit (SAP) for the first time. 3. The Registrar’s office will evaluate if lack of credit (SAP) is for a second semester. • If it is the second semester, the student is then notified and they are no longer eligible for federal financial aid for the upcoming term. • The Financial Aid office will provide notification to the student that credit is needed for that semester or the student is not eligible for federal financial aid for the upcoming term. • The Registrar’s office will provide notification of students on the list created in point 2 and 3 to the Financial Aid office. 4. Financial Aid will update student’s record to indicate that they are ineligible for financial aid. This process will remain in place until Goddard College completes implementation of “Anthology Student” which is an integrated student information system that supports compliance with Title IV guidelines. Anthology will evaluate satisfactory academic progress against an approved program, among many other compliance items, and provide the integrated notification to students of their lack of progress as well as flag their financial aid record so that federal funds are not approved. This system will replace the intensive manual data management process currently utilized and the electronic alerts and processes will achieve results reliably and automatically. The college would like to note that the registrar (the student in question) did not provide written notification that she did not meet SAP from the Fall term but she was aware of it given her position and normal job duties. The employee involved has submitted their resignation from the college and the process will be shared with the new Registrar. Financial aid staff has completed additional training on SAP guidelines and the importance of compliance with SAP requirements.

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Other Findings in this Audit

  • 370501 2023-001
    Significant Deficiency
  • 370502 2023-001
    Significant Deficiency
  • 370503 2023-001
    Significant Deficiency
  • 946942 2023-001
    Significant Deficiency
  • 946943 2023-001
    Significant Deficiency
  • 946944 2023-001
    Significant Deficiency
  • 946945 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $4.73M
84.063 Federal Pell Grant Program $327,336
84.038 Federal Perkins Loan Program $192,610
84.007 Federal Supplemental Educational Opportunity Grants $87,854