Finding 38522 (2022-001)

November 1, 2022 Finding 2022-001: 2022-001 Special Tests and Provisions ? Verification Management?s View and Corrective Action Plan Through review and analysis of the finding during the audit, management notes two staff members incorrectly processed the files for the four federal verification issues identified. Three of the four files were processed by a staff member who no longer works at the University, and one of the four files was processed by a current Sr. Counselor. The Sr. Counselor responsible for one of the errors has had additional training provided to ensure the clear understanding of the data elements required on the Free Application for Federal Student Aid (FAFSA)/Institutional Student Information Record (ISIR), with particular emphasis on the taxes paid as this can produce a change to the need and potential change to the federal aid awarded. The Office of Student Financial Assistance (OSFA) will continue to require annual training on the FAFSA/ISIR and federal verification process for all staff who review student records. Training for the upcoming cycle will start in November 2022, prior to the incoming freshmen student file review processing scheduled to begin in December 2022. The training will have a strong emphasis on the data elements that are required to be verified with a data element matrix to be used as a reference tool. This tool will be required to be utilized when completing the verification process. Beyond the initial start to the cycle training, we will continue ongoing training and refreshers throughout the year. Additionally, starting with the new cycle, OSFA?s management team will be implementing a second level review process for all verified files. This will require that an OSFA manager complete an additional review to identify any potential errors. The OSFA manager will also be responsible for providing training needs throughout the processing cycle. In addition, a peer review process will be implemented on a sample basis to maintain a stronger environment of accountability. The second level and peer review process will be ongoing. For the longer term, OSFA is in the process of hiring a Chief Financial Aid Compliance Officer, backfilling a current vacancy. OSFA is working to enhance the position to ensure a compliance officer with necessary skills and Title IV knowledge will be hired. This will allow the office to have regular evaluation and staff training of policies and procedures, as well as performing desk audits throughout each cycle to identify potential risks and create action plans for staff members that need additional assistance. Implementation Date: November 2022 Estimated Completion Date: The training and enhanced review process will be ongoing and the Chief Financial Aid Compliance Officer position is aimed to be filled in FY23. Responsible Official and Point of Contact: Michelle Arcieri, Executive Director for Student Financial Assistance Neena Ali Associate Vice President & Controller