Finding 2023-001: Student Financial Assistance Cluster – Eligibility – Award Limits
Name of Contact Person: Alice Herrick, Director of Fiscal Operations; Ryan French, Director of Financial Aid
Corrective Action Plan
Introduction: This Corrective Action Plan addresses the significant deficiency identified in the audit regarding the review of student enrollment data prior to loan approval. The deficiency resulted in one noted student receiving a federal loan disbursement above their annual eligibility limit, and two students who each received a federal loan disbursement below their annual eligibility limit. We acknowledge the issue and have implemented immediate corrective measures to rectify the situation and prevent recurrence.
Root Causes Analysis: The deficiency stemmed from two main factors:
a. Limitations of PowerFAIDS: The software lacks automated quality control mechanisms to prevent overawarding or overdisbursement. Additionally, the software’s database design poses a challenge due to the “one-to-many” relationship of Periods of Enrollment (POE), making automated packaging algorithms which address this deficiency impossible.
b. Staff Awareness: Financial aid staff were unaware of PowerFAIDS' limitations and lacked clear guidance on necessary quality control procedures.
Immediate Corrective Actions Implemented: In response to the deficiency, the following actions have been taken:
a. Manual Quality Control Procedure: A manual review process has been established prior to each semester's disbursement date. This process includes verifying student enrollment data and identifying discrepancies between self-reported class levels (PF: "F-YR-SCHOOL") and official class progression (PC: "academic_class_level", PF: "POE-YR-SCHL").
b. Repackaging and Communication: Students with verified discrepancies in class levels are repackaged accordingly and updated financial aid offer letters/emails are sent to notify students of changes and request their consideration.
Confirmation of Effectiveness: A thorough review of the 2023-2024 academic year data confirms that no current students have been awarded or disbursed above their annual eligibility limit, validating the effectiveness of the implemented quality control procedure.
Future Mitigation Strategies: To further mitigate the risk of noncompliance and reduce manual review time, the following strategies will be implemented:
a. Dynamic Custom Field in PowerFAIDS: Proposing the creation of a dynamic custom field (e.g., “PC_ACL_Progression”) that updates student class levels via API integration with PowerCampus.
b. Automated Packaging Rule: Developing an automated packaging rule within PowerFAIDS based on the dynamic custom field to identify Year In School (YIS) mismatches and trigger necessary repackaging. This rule will incorporate the YIS Mismatch quality control function and algorithm, reducing the time commitment necessary for manual review.
Timeline for Implementation: While a current manual process is in place, the proposed future mitigation is forthcoming.
a. Manual Quality Control Procedure: This procedure was put into effect by Financial Aid staff on November 16th, 2023, and was successfully implemented prior to Spring 2024 disbursement. All current disbursements of Federal TitleIV aid have been made in accordance with U.S. Department of Education criteria.
b. Future Mitigation: The proposed dynamic custom field and automated packaging rule will be developed and implemented within the next academic year to streamline the quality control process and enhance compliance measures.
Conclusion: Maine Maritime Academy is committed to ensuring compliance with U.S. Department of Education regulations and providing accurate and appropriate financial aid awards to students. The corrective actions outlined in this plan address the deficiencies identified in the Uniform Guidance audit and aim to prevent similar issues in the future. We appreciate the audit findings and remain dedicated to continuous improvement in our financial aid procedures.
Name of Contact Person: Alice Herrick, Director of Fiscal Operations; Ryan French, Director of Financial Aid
Corrective Action Plan: The Academy will review current procedures related to awarding Unsubsidized and Subsidized loans and implement additional review procedures to ensure awards to students are appropriately within limits set by the Department of Education.
Planned Completion Date: June 2024